Betty J. Shackelford - Page 18

                                         - 18 -                                       
          bears the notation "Insurance".  However, petitioner did not offer          
          or provide health insurance to any other employee.  Moreover,               
          petitioner has provided no evidence that a check written to Maynard         
          & McDonald substantiates an employee health insurance expense.  We          
          find that petitioner has failed to establish that these                     
          expenditures were incurred primarily for business reasons.  Henry           
          v. Commissioner, supra; Larrabee v. Commissioner, supra.                    
               Petitioner claimed a deduction for a check in the amount of            
          $200 payable to Renata.  Petitioner contends that the check                 
          represented reimbursement of mileage incurred by her employee.  The         
          check bears the notation "Mileage 11/29-12/15/89".  However, it was         
          not petitioner's practice to reimburse employees for mileage in a           
          separate check.  Instead, employees reported mileage on their               
          biweekly time sheets and were reimbursed in their regular pay               
          checks.  This practice applied to Renata as well.  Petitioner has           
          provided no credible evidence to explain why this particular                
          reimbursement was handled out of the ordinary course.  Accordingly,         
          we uphold respondent's disallowance of this deduction.                      
               Petitioner claimed a deduction for payments of $1,100 and $500         
          to Florin Road Nissan as a downpayment for a car for Renata.                
          Petitioner testified that it was necessary for Renata to travel as          
          part of her job responsibilities.  Petitioner further testified             
          that after Renata had been working for a few weeks, her car failed,         
          and petitioner agreed to help Renata purchase a new car to                  
          facilitate her business-related travel.  Petitioner handled the             




Page:  Previous  8  9  10  11  12  13  14  15  16  17  18  19  20  21  22  23  24  25  26  27  Next

Last modified: May 25, 2011