- 3 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 NextLast modified: November 10, 2007