World of Service, Inc. - Page 5

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          deducted expenditures related to the condominium in excess of 10            
          percent.                                                                    
            Service also deducted $2,101, $2,178, and $5,018, and                     
          respondent disallowed $1,284, $1,362, and $3,403 for 1982, 1983,            
          and 1984, respectively.  These deductions were for utilities,               
          trash removal, pest control, telephone, etc.  The largest portion           
          of these amounts was attributable to telephone expenses.                    
            Service made the following expenditures, which were deducted in           
          the tax year paid and were disallowed by respondent as being                
          without a business purpose:                                                 
            Date         Payee                              Amount                    
          05/19/82       Baby Safety Industries             $225                      
           10/03/82     Dicker & Dicker of Beverly Hills       1,915                  
           11/08/83       Dicker & Dicker of Beverly Hills      115,020               
              1 Only $14,154 of this amount was included in Service's cost            
           of goods sold.                                                             
           Four different styles of mink coats had been purchased from                
           Dicker & Dicker of Beverly Hills, a furrier.  Some of the fur              
           coats were used by Great for business purposes; however,                   
           petitioners have failed to show that the coats purchased during            
           1982 or 1983 were used for business purposes.  A "Wanda chair"             
           had been purchased from Baby Safety Industries to be given, as             
           a gift, to the owner of a company from which Service was to                
           obtain technology for its computer operations.                             
             Service leased a Mercedes-Benz automobile, paying $915 per               
           month.  During 1983 and 1984, Service deducted, and respondent             





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