- 6 -
directed towards improving the lives of young basketball players
in urban Chicago. Aside from a Schedule C for DMR, which was
attached as part of the stipulated exhibits, the record is devoid
of any other mention of this activity. Petitioner did not file a
Schedule C with respect to DMR in either 2001 or 2002.
For taxable years 2000, 2001, and 2002, petitioner filed
Schedules C for RBS as follows:
2000 2001 2002
Income $3,000 $3,850 $2,450
Business Expenses
Advertising 44 400 -
Bad debts - 275 -
Insurance 350 - -
Vehicle rental 840 - 1,725
Property rental 1,365 - -
Car and truck - 1,466 3,078
Office expenses - - 500
Utilities 1,154 1,556 3,916
Taxes and licenses - - 200
Travel, meals
and entertainment - 4,390 -
Supplies - 200 2,425
Other 19,536 13,605 13,150
Total expenses 23,28921,892 24,994
Net profit or (loss) (20,289) (18,042) (22,544)
In the notice of deficiency mailed to petitioner, respondent
disallowed all of the business expenses claimed by petitioner on
the Schedules C for RBS in 2000, 2001, and 2002, because
petitioner had neither established that any of the amounts
constituted an ordinary and necessary business expense nor
provided any documentation to substantiate the claimed expenses.
Respondent also recharacterized the amounts of income as listed
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: November 10, 2007