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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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