Jasbinder Singh - Page 2




                                         -2-                                          
               After concessions,2 the issue for decision is whether                  
          petitioner is entitled to deduct on Schedule C, Profit or Loss              
          From Business, certain expenses in excess of those respondent               
          conceded.                                                                   
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts, the exhibits attached thereto, and the            
          stipulation of settled issues are incorporated herein by this               
          reference.   At the time he filed his petition, petitioner resided          
          in Modesto, California.                                                     
               During 2004, petitioner owned his own commercial truck and             
          was self-employed as a truck driver.  Petitioner used his truck             
          to transport cargo throughout the San Francisco Bay area for one            
          client, GSC Logistics.  While not making deliveries, petitioner             
          parked his truck at a yard owned by GSC Logistics.  He traveled             
          between his residence and the yard using his Ford Mustang.  On              
          his 2004 Form 1040, U.S. Individual Income Tax Return, petitioner           
          claimed $82,428 of Schedule C expenses with respect to his truck            
          driving.  On July 19, 2006, respondent issued petitioner a notice           
          of deficiency, disallowing $71,723 of those expenses.                       


               1(...continued)                                                        
          to the nearest dollar.                                                      
               2Respondent conceded that petitioner is entitled to $42,648            
          of Schedule C expenses.  Respondent further conceded that                   
          petitioner is not liable for a sec. 6662(a) penalty.                        





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