- 29 - shareholders.” Markwardt v. Commissioner, 64 T.C. 989, 995 (1975). Petitioners on their 1986 Schedule C claimed deductions for: Insurance--$100, mortgage interest--$69,860, taxes--$340, and contract labor--$69,850. Petitioners, on their 1989 Schedule C claimed deductions for: Insurance--$7,945, mortgage interest-- $65,639, taxes--$8,050, and repairs--$14,490. Petitioners have not demonstrated that the expenses were incurred for the vending machines that petitioners have claimed they owned. The record does not reflect that the expenses were paid or incurred during the tax years 1986 and 1989. In addition, petitioners have not shown that any such items were ordinary and necessary business expenses. Sec. 1.162-1(a), Income Tax Regs. Petitioners contend that, in 1986, they owned 70 vending machines out of the total of 490 and that they prorated all corporate operating expenses between the vending machines alleged to be theirs and the total. However, petitioners presented no evidence demonstrating the proration or allocation between the vending machines claimed by petitioners and the corporate vending machines. It should also be noted that PWIC, PWMC, and C.B. Crest, in addition to commercial water purification, leased systems for home use. Petitioners conceded on brief that they failed toPage: Previous 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 Next
Last modified: May 25, 2011