Yuri G. Glotov - Page 3




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          claimed a depreciation deduction of $3,4792 for the business use            
          of his 2001 Ford Taurus SES (Ford Taurus).  Petitioner did not              
          elect to amortize these deductions as startup expenditures under            
          section 195(b).                                                             
               In September 2005, respondent initiated an audit of                    
          petitioner’s 2003 return.  As part of the audit, respondent                 
          requested petitioner to provide documentation to substantiate the           
          Schedule C car and truck expense of $3,977, the labor expense of            
          $7,070, and the depreciation deduction of $3,479 (business                  
          deductions at issue).                                                       
               At a meeting, on October 4, 2005, between respondent’s and             
          petitioner’s representatives, petitioner’s representative3 did              
          not provide any documentation to substantiate these deductions or           
          to show petitioner was carrying on a computer software business             
          in 2003.  On October 24, 2005, petitioner provided respondent               
          with documentation in an attempt to substantiate the Schedule C             
          car and truck expense and the depreciation deduction but provided           
          no documentation to substantiate the labor expense or to show he            
          was carrying on a computer software business in 2003.                       



               2 The deprecation deduction of $3,479 was determined using             
          the 200 percent declining balance method and half-year                      
          convention.  See sec. 168(b), (d).                                          
               3 Petitioner’s representative was not an enrolled return               
          preparer, did not sign as a preparer on petitioner’s 2003 return,           
          and was not admitted to practice before the Tax Court.                      





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