Greta Ann Clifton - Page 11

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          three individual accounts.  On her 1985 Federal income tax                  
          return, petitioner deducted the entire $105 in bank charges. In             
          her notice of deficiency, respondent disallowed this deduction.             
               Petitioner argues that, since she conducted her Avon                   
          business through these three accounts, the service charges are              
          deductible.  However, petitioner conceded that she also used the            
          accounts for "personal" purposes.  Petitioner did not attempt to            
          quantify the personal use versus the business use.  Respondent              
          conceded that petitioner was entitled to deduct $24 of the $105             
          in service charges, apparently recognizing that the portion of              
          the service charges attributable to the Avon business was                   
          deductible.  Petitioner has failed to substantiate that the                 
          remaining $81 claimed was a deductible business expense.                    
          Therefore, we sustain respondent's determination.                           
               B.  Car and Truck Expenses                                             
               Petitioner claimed a deduction of $1,564 for car and truck             
          expenses on Schedule C of her 1985 Federal income tax return.               
          Respondent determined that only $420 of such amount was                     
          allowable.  Petitioner asserts that the entire amount claimed is            
               When a taxpayer uses a vehicle for both business and                   
          personal purposes, she must produce sufficient evidence by which            
          this Court can determine what portion of such expenses was for              
          business purposes and what portion was for personal purposes.               
          Cobb v. Commissioner, 77 T.C. 1096, 1101 (1981).                            

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