- 10 -
Expenses Amount
Other expenses 1$16,055
Meals and entertainment 2,140
Travel 460
Legal and professional services 459
Car and truck expenses 824
Total 19,938
1 “Other expenditures” are enumerated on petitioner’s return
as follows:
Expenses Amount
Club memberships $172
Copyright registration 1,890
Dues and subscriptions 320
Framing 280
Membership fees 175
Parking 848
Photography 685
Postage 1,043
Professional development 4,250
Storage fees 440
Subscriptions and publications 199
Telephone 5,753
Total 16,055
On brief, respondent disputes the entire $32,018 of claimed
Schedule C expenses for 2003. Section 6214(a) provides that this
Court shall have jurisdiction to redetermine the correct amount
of the deficiency, even if the amount so redetermined is greater
than the amount determined by the Commissioner in the notice of
deficiency, if the Commissioner asserts a claim at or before the
hearing or rehearing. Consistent with the general mandate of
section 6214(a), this Court generally will exercise its
jurisdiction over an increased deficiency only where the matter
is properly pleaded. See Estate of Petschek v. Commissioner, 81
T.C. 260, 271-272 (1983), affd. 738 F.2d 67 (2d Cir. 1984); see
also Markwardt v. Commissioner, 64 T.C. 989, 997 (1975). Because
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Last modified: March 27, 2008