Lisa J. Tomlinson - Page 10




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          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.                                                                         






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