John Edward Kerrigan and Joan Marie Kerrigan - Page 9

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            Safeway (a grocery store) or Britches (a clothing store), rather                           
            than to the daughters themselves.  In addition, Mrs. Kerrigan                              
            failed to record these checks in her business log or to provide                            
            her children with Forms W-2 or 1099.  Petitioners have failed to                           
            substantiate any deductions in excess of the amount already                                
            allowed by respondent.                                                                     

            Depreciation                                                                               

                  Petitioners also claimed a deduction on Mrs. Kerrigan's                              
            Schedule C for depreciation in the amount of $5,030.  Respondent                           
            allowed $2,386.  Petitioners on brief again argue that they are                            
            entitled to a larger depreciation deduction than they originally                           
            claimed.                                                                                   
                  Mrs. Kerrigan claimed a depreciation deduction for three                             
            items:  Her 1985 Oldsmobile Toronado, her "office" in                                      
            petitioners' house in Potomac, Maryland, and a condominium that                            
            petitioners owned in Ocean City, Maryland, which Mrs. Kerrigan                             
            allegedly used as an office.  We find several difficulties with                            
            Mrs. Kerrigan's depreciation deduction.  First, petitioners have                           
            not offered sufficient evidence of Mrs. Kerrigan's cost basis in                           
            the Toronado.  Second, we repeat our inability to understand how                           
            Mrs. Kerrigan arrived at a figure of "96 percent business use"                             
            for the vehicle.  Thus, we have no way of knowing if this is a                             
            proper allocation between business and personal use.  In                                   
            addition, petitioners have failed to provide us with any evidence                          
            of Mrs. Kerrigan's cost basis in petitioners' house in Potomac.                            



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