- 9 -
respondent’s disallowance of petitioner’s 2002 Schedule C
deductions was proper.7
Petitioner’s return for 2003 contains a Schedule C on which
she reported zero gross receipts and a net loss of $32,018 for
“Temps To Go”. The Schedule C for Temps To Go is the only
Schedule C attached to the 2003 return. Petitioner testified
that the expenses claimed on her Schedule C for 2003 were
actually expenses incurred in another business called “Gotta Get
Up Productions”.8 Petitioner claimed that she held a 100-percent
interest in Gotta Get Up Productions in 2003.
In the notice of deficiency, respondent disallowed the
following claimed deductions for expenses listed on petitioner’s
2003 Schedule C:
7 We note that many of the claimed expenses were clearly
personal as opposed to business expenses. These included:
Travel expenses paid for with petitioner’s Versata, Inc., credit
card for a stay at the Oakland Marriott while her house was being
restored after experiencing water damage caused by a leaky roof;
expenses associated with a tennis club membership; expenses for
the rental of other business property for a studio that her
brother Jon Tomlinson leased in September 2002; travel expenses
for four rooms at the Dayton Marriott for petitioner’s family to
attend an event featuring petitioner’s brother Jon’s art; and
expenses for the entire cost of petitioner’s health, life,
disability, homeowner’s, and automobile insurance. Many other
claimed expenses were unsubstantiated.
8 Petitioner also testified that she was unsure whether any
of the expenses claimed on the 2003 Schedule C relate to Temps to
Go.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: March 27, 2008