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checks at the banks on which they were drawn. Petitioner paid
workers and paid other expenses in cash. During 2001, petitioner
used an extended-cab pickup truck to transport his crew and
materials to tile jobs.
Petitioner did not make any estimated tax payments and did
not pay any withholding taxes in 2001. Petitioner did not file a
tax return for either 2000 or 2001.
Pursuant to section 6020(b), respondent prepared a
substitute for return for 2001. Respondent included self-
employment income reported on Forms 1099-MISC, Miscellaneous
Income, and Social Security benefits reported on Form SSA-1099,
Social Security Benefit Statement, on the substitute for return.
Respondent allowed a personal exemption and a standard deduction
on the substitute for return.2 Respondent issued a notice of
deficiency. Petitioner timely filed a petition for
redetermination.
Discussion
The parties have stipulated the items of income but dispute
whether petitioner is entitled to deductions for expenses related
to his tile business.3 Petitioner did not submit a Schedule C,
2 As indicated supra note 1, respondent concedes the filing
status and home mortgage interest deduction.
3 Respondent does not dispute that petitioner’s installation
of tile in 2001 qualifies as a trade or business for Federal
income tax purposes. On the record as a whole, the Court presumes
(continued...)
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