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Expenses, and reported the following:
Business miles driven during 2003 28,744 miles
Other miles driven 17,036 miles
Total miles driven 45,780 miles
Percentage of business use 62.790 %
Standard mileage rate $0.36/business
x Business miles x 28,744 miles
Deduction $10,348
Somewhat inconsistent with the foregoing, petitioner also
attached to his return a Schedule C-EZ, Net Profit From Business.
On this schedule, petitioner reported nonemployee compensation
from Consolidated Education Resources, LLC, of $6,215, but
reported no expenses, claiming them instead on Schedule A as
unreimbursed employee expenses, as discussed in the preceding
paragraph. However, petitioner did report, and pay, self-
employment tax on the basis of nonemployee compensation of $6,215
without reduction for any expense.3
Notice of Deficiency and Petition
In the notice of deficiency, respondent determined that
petitioner had failed to substantiate the deductions claimed for
charitable contributions and employee business expenses.
Accordingly, respondent disallowed those two deductions in their
3 Petitioner also claimed a so-called above-the-line
deduction for one-half of the self-employment tax reported. See
sec. 164(f).
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Last modified: March 27, 2008