World of Service, Inc. - Page 6

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           disallowed for lack of a business purpose, the auto lease                  
           payments in the total amounts of $11,347 and $11,151,                      
           respectively.  This automobile was used, in part, for business             
           and, in part, for personal purposes.  For 1982, 1983, and 1984,            
           Service deducted, and respondent disallowed for lack of                    
           business purpose, $2,631, $2,513, and $8,717 of expenditures in            
           connection with the maintenance and operation of a 1977                    
           Eldorado.  During the period under consideration, three                    
           automobiles were used by the Johnsons in connection with the               
           businesses:  The 1977 Eldorado, the leased Mercedes-Benz, and a            
           1980 Buick.  The automobiles were used for both business and               
           personal purposes.                                                         
             During 1983, Service purchased a beach condominium (beach                
           condo) for about $140,000.  Improvements and furnishings of                
           approximately $20,000 to $22,000 were added.  The Johnsons                 
           occasionally used the beach condo for personal use.  Service               
           claimed $1,057 for 1983 as "Mortgage Service Expense", and the             
           claimed amount consisted of loan prepayments, transfer stamp               
           tax, and related fees in connection with the purchase of the               
           beach condo.  Respondent disallowed the amount for lack of a               
           business purpose.  Service, in connection with the beach condo,            
           deducted $7,186 and $410 for 1983 and 1984, respectively, for              
           decorating.  Of the $7,186, $1,904 was allowed by respondent               
           because it was for decorating corporate offices, and the                   
           remainder of these amounts, which involved the beach condo,                




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