John Edward Kerrigan and Joan Marie Kerrigan - Page 7

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            total for these items was $3,617.01.4  Petitioners' daughters                              
            testified that Mrs. Kerrigan frequently purchased such items in                            
            the course of her business.  The expenditures reflected in the                             
            log are reasonable considering Mrs. Kerrigan's position as a                               
            successful realtor specializing in the sale of expensive houses.                           
            We hold that petitioners are entitled to deduct $3,617.01 for                              
            Mrs. Kerrigan's advertising expenses.                                                      

            Car and Truck Expenses                                                                     

                  Mrs. Kerrigan claimed a Schedule C deduction for car and                             
            truck expenses in the amount of $2,838.50.  Of this amount,                                
            respondent allowed $2,055.  On brief, petitioners argue that they                          
            are actually entitled to a greater deduction than originally                               
            claimed.                                                                                   
                  Petitioners argue that Mrs. Kerrigan incurred gasoline and                           
            insurance expenses of $3,093.12 on her 1985 Oldsmobile Toronado.                           
            In arriving at this figure, it appears that petitioners counted                            
            certain expenditures from Mrs. Kerrigan's log twice.  The log                              
            indicates that Mrs. Kerrigan's total business expenses for the                             
            Toronado in 1985 were $2,477.  Yet, when calculating their                                 
            expenses on brief, petitioners add to this figure the amounts of                           
            $238 and $507.  However, these expenses had already been taken                             


            4Mrs. Kerrigan had expenditures of $2,035.04 for signs,                                    
            $1,195.27 for items for open houses, and $386.70 for business                              
            "gifts".                                                                                   




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