Andrew Wesley Frank & Joy Mary Frank - Page 14

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                       b.   The Food Supplement Business                              
               Petitioners lost the log which listed their automobile use             
          for the food supplement business from May to December 1991.  In             
          lieu of a mileage log, petitioners introduced numerous receipts             
          to support their claim that they participated in that business              
          from May to December 1991.                                                  
               Petitioners offered a summary of income and expenses of                
          their food supplement business.  The list was marked with the               
          letters "KM".  It listed 17 expenses, such as $7 in bridge tolls,           
          $6.52 for postage, $10.81 for failure to collect taxes on sales             
          made, and 50 cents for parking.  Mr. Frank testified that he                
          spent these amounts for his food supplement business.  We hold              
          that petitioners may deduct $24.83 for these expenses.                      
                       c.   The Nebraska Street Property                              
               Petitioners offered no evidence relating to automobile                 
          expenses for the Nebraska Street property.  They have not met               
          their burden of proof for this expense.  Rule 142(a).                       
               3.      Whether Petitioners May Deduct Expenses Related to             
               Their Purchase of the Springs Road Property                            
               Amounts paid in connection with the acquisition of property            
          are capital expenditures if they increase the value or                      
          substantially prolong the useful life of the property.  Sec.                
          1.263(a)-1(b), Income Tax Regs.  Amounts paid or incurred for               
          repairs and maintenance are not capital expenditures.                       







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