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3. The Mercedes-Benz, Buick, and Eldorado automobiles were
used one-half for business and one-half for personal purposes
during the years in controversy. One-half of the amounts
claimed by Service for depreciation, gasoline, and repairs and
maintenance of those automobiles is deductible. It has not
been shown that any portion of disallowed claimed foreign
travel was deductible for business purposes of Service or
Great.
4. The GMC truck was not used for business purposes during
the years in controversy. No depreciation or tax credits are
allowable for the GMC truck. Gasoline purchased with the AMOCO
credit card within North Carolina is not deductible because it
was purchased for the personal use of the GMC truck by Mr.
Johnson's father.
5. Service purchased a Wanda chair from Baby Safety
Industries for $225 as a gift for a business purpose. That
amount is deductible for Service's 1982 tax year.
6. It has not been shown that the fur coats purchased from
Dicker & Dicker of Beverly Hills during 1982 or 1983 were for a
deductible business purpose.
7. Petitioners have not shown that they are entitled to any
of the claimed net operating loss deductions or tax credit
carryovers for the taxable years under consideration.
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