Eng Guek Kang - Page 18




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          1995.  Of this amount, we find that $5,657.62 was substantiated             
          from the description of the expense in the business ledger.                 
          Although Mr. Ngo only claimed a repair/maintenance expense of               
          $315, we find that he is entitled to a deduction of $5,657.62.              
               Likewise, Mr. Ngo’s business ledger shows a total of                   
          $16,347.87 in repair/maintenance expenses.  After review of the             
          business ledger and notations contained therein, we find that Mr.           
          Ngo is entitled to a deduction of $14,730.55 for repair/                    
          maintenance expenses in 1996.                                               
               In 1997, Mr. Ngo did not claim a repair/maintenance expense            
          deduction.  However, in our review of his legal and professional            
          fees above, we found that many of the entries were erroneously              
          categorized as legal and professional fees.  Of the misplaced               
          entries, we find that $3,552.83 was properly recharacterized as             
          repair/maintenance expenses.  Furthermore, after reviewing Mr.              
          Ngo’s entire business ledger for 1997, we find that he is also              
          entitled to a deduction for repair/maintenance expenses of                  
          $3,910.67.  Accordingly, for 1997 Mr. Ngo is entitled to a total            
          deduction of $7,473.50 in repair/ maintenance expenses for 1997.            
               5.  Salary/Wages                                                       
               Mr. Ngo claimed salary/wages deductions of $12,000, $12,000,           
          and $12,618, respectively, for the years at issue.  Respondent              
          allowed $10,329, $8,465, and $4,618, respectively.                          
               Reasonable compensation for services actually rendered is              






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