Darryl F. Royster - Page 7




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          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             






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