Kent Maerki and Kathleen Turner - Page 10

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          "other" expenses was interest of $3,255.29 paid on a home equity            
          loan.  Petitioner testified that the loan proceeds from this loan           
          were used in his business, but he provided no supporting                    
          documents to establish this.  We also find it curious that a                
          deduction for $3,255.29 of alleged business interest would be               
          buried in a $20,110.29 business deduction classified as "other"             
          when the Schedule C provides a specific line for interest                   
          deductions.  In any event, based on the record before us,                   
          petitioners have failed to prove entitlement to a business                  
          deduction for interest.6                                                    

          Issue 3.  Education Expenses on Schedule C for ENT                          

               On the Schedule C for ENT, petitioners deducted expenses of            
          over $135,000.  Respondent has disallowed $8,951 of those                   
          Schedule C deductions.                                                      
               Petitioners claimed a deduction for education expenses on              
          the Schedule C for ENT in the amount of $8,951.  Petitioner                 
          testified that $5,000 of this amount was attributable to the cost           
          of a training seminar for Jon Palmieri, an ENT employee.                    
          Petitioners produced a canceled check to "The Estate Plan" that             
          indicates it was for training for Mr. Palmieri.  The "Profit and            
          Loss" statement for ENT for the year ended December 31, 1990,               


          6Petitioners presumably could have elected to deduct this                   
          interest as an itemized deduction.  Instead, they elected to use            
          the standard deduction.                                                     




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