World of Service, Inc. - Page 7

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           were disallowed for lack of a business purpose.  Service, for              
           1984, paid and deducted other amounts connected with the beach             
           condo, which respondent disallowed.  For 1984, Service deducted            
           $1,362 as association fees, part of which was for the beach                
           condo and part of which was for the Johnsons' residence.                   
           Respondent allowed $57, representing 10 percent business use of            
           the residence, and the remainder was disallowed for lack of a              
           business purpose.                                                          
             For 1982, Service deducted the amount of certain MasterCard              
           charges that were designated as "Seminar Training Program                  
           Costs" and disallowed by respondent for lack of a business                 
           purpose.  For 1982, 1983, and 1984, Service deducted $2,172,               
           $2,008, and $1,797 for dues, subscriptions, and memberships,               
           including the annual condominium fee of $720 for the Johnsons'             
           residence.  Respondent, asserting the lack of a business                   
           purpose, disallowed $2,076, $1,903, and $1,732 of the these                
           amounts (10 percent of the condominium fees were allowed).                 
             Service deducted $6,891, $8,800, and $7,694 for automobile               
           insurance expenses, and respondent disallowed, for lack of a               
           business purpose, $6,801, $8,470, and $7,609 (10 percent of the            
           fees that related to the condominium were allowed).                        
             Service also deducted for the years 1982, 1983, and 1984                 
           travel, meals, lodging, convention, and entertainment expense              
           amounts totaling $8,671, $6,276, and $19,443, and respondent               
           disallowed, for lack of a business purpose, all but $180 for               




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Last modified: May 25, 2011