World of Service, Inc. - Page 13

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           the 1983 amount for lack of substantiation and business                    
           purpose.  For 1982 and 1983, Great deducted $530,667 and                   
           $351,983 in net operating loss carryover deductions from the               
           FYE July 31, 1982.  Respondent disallowed the claimed loss                 
           deductions because Great had been the subject of an audit for              
           years prior to those now before the Court.  In a case involving            
           the prior years which was pending before this Court, the same              
           net operating losses were eliminated due to the parties' agreed            
           settlement.  Great had agreed to an income tax deficiency,                 
           rather than a loss, in the earlier case.                                   
                              ULTIMATE FINDINGS OF FACT                               
             1.  Service, for each of its 3 taxable years, is entitled to             
           deduct 20 percent of the costs and expenses connected with the             
           business use of the Johnsons' residence (condo) including the              
           utilities, with the exception of the cost of telephone service,            
           for which Service is entitled to deduct 75 percent for 1982 and            
           1983 and 100 percent for 1984.  Service is also allowed to                 
           deduct 20 percent of the condominium association fees, rather              
           than the 10 percent allowed by respondent.                                 
             2.  Service is not entitled to deduct any expenses,                      
           depreciation, or other claimed amounts connected with the beach            
           condo, including decorating and furnishing expenditures and                
           association and condo fees.  The $1,057 that Service claimed               
           for 1983 as "Mortgage Service Expense" for closing costs on the            
           beach condo is not deductible.                                             




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