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nonbusiness property (including a General Motors Corp. (GMC)
truck, 1980 Buick, copper sculpture, and the beach condo). The
GMC truck had been purchased with the intent to use it in the
Service and Great businesses; however, it was not suitable.
Mr. Johnson allowed the GMC truck to be used on a farm by his
father, which was not shown to be for a business purpose of
Service. Mr. Johnson's father purchased gasoline with an AMOCO
gasoline credit card in the general vicinity of his home in
Dunn, North Carolina, for personal use of the GMC truck.
Service, for 1982, 1983, and 1984, claimed net operating loss
carryover deductions from 1981 in the amounts of $143,814,
$134,401, and $30,851, respectively, and respondent disallowed
them because the 1981 tax year, after controversy and
settlement by the parties, resulted in an income tax deficiency
and no amount of carryover loss. Service, for 1984, claimed
investment tax credit carryovers from 1982 and 1983 in the
amounts of $659 and $2,226, respectively, which respondent
disallowed as being attributable to nonbusiness property (a GMC
truck and beach condo furniture).
Great, for its FYE July 31, 1983, treated $5,000 as part of
its cost of goods sold for the purpose of making copies of 24
promotional tapes. The old tapes had become worn from use.
Great, for 1982, included $39,627 as part of its cost of goods
sold, for convention expenses, and respondent disallowed $158
as not being an ordinary and necessary business expense.
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