Lisa J. Tomlinson - Page 7




                                        - 6 -                                         
          of business potential.  Dean v. Commissioner, 56 T.C. 895, 902              
          (1971); Glotov v. Commissioner, T.C. Memo. 2007-147.                        
               Personal, living, or family expenses are not deductible.               
          Sec. 262.  Similarly, deductions for expenditures that are                  
          properly categorized as capital expenditures are not allowable.             
          Sec. 263.  In order for petitioner to be entitled to deduct her             
          claimed Schedule C expenses she must satisfy the requirements of            
          section 162.  Additionally, certain expenses warrant the                    
          heightened substantiation requirements of section 274(d) and the            
          regulations thereunder.                                                     
               Petitioner’s return for 2002 contains a Schedule C for “ASIL           
          Investments” on which she reported zero gross receipts and a net            
          loss of $77,267.  Respondent disallowed all of the claimed                  
          deductions for expenses, which were listed on petitioner’s 2002             
          Schedule C as follows:                                                      
          Expenses                             Amount                                 
          Car and truck expenses                    $1,230                            
          Depreciation                               4,196                            
          Insurance                                  1,600                            
          Legal and professional services           12,115                            
          Office expense                            10,132                            
          Rent or lease of other business            4,152                            
          property                                                                    
          Supplies                                   5,936                            
          Travel                                    10,706                            
          Meals and entertainment                    5,845                            
          Wages                                      1,490                            
          Accounting                                 1,832                            
          Answering service                            495                            
          Club membership                            3,170                            
          Delivery and freight                         757                            
          Gifts                                      1,226                            






Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  Next 

Last modified: March 27, 2008