Andrew Wesley Frank & Joy Mary Frank - Page 19

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          identified.  The receipt has "501" written on it.  While the                
          record does not show when petitioners bought the Nebraska Street            
          property, petitioners reported income from it on their 1990 tax             
          return.  Petitioners have not explained how a 1991 recording fee            
          relates to property they owned at least since 1990.                         
               Petitioners introduced a receipt from Solano Superior Court            
          for copies and forms dated August 20, 1991.  They did not show              
          what copies were made or whether they were made for a business              
          purpose.                                                                    
               Petitioners introduced a receipt for a $20 plumbing expense            
          dated September 26, 1991, a receipt for $75 paid to Sullivan                
          Industries, Inc., for an inspection fee for the Nebraska Street             
          property dated April 29, 1991, and about 23 receipts from stores            
          including Yardbirds, Orchard Supply Hardware, Newcomb & Son,                
          Inc., Homeclub, Payless Drug, Dan's Ace Hardware, Standard Brands           
          Paint & Home Decorating Center, and the Solano County Recorder's            
          Office.  Mr. Frank testified that these expenses were for general           
          maintenance of the Nebraska Street property.  We hold that                  
          petitioners may deduct these expenses.                                      
          C.  Points                                                                  
               A taxpayer may generally deduct interest paid or accrued on            
          indebtedness.  Sec. 163(a).  Interest is compensation for the use           
          or forbearance of money.  Deputy v. Du Pont, 308 U.S. 488, 498              








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