William W. Halle IV, and Janice C. Halle - Page 18

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                         Taxes               6,150.72                                 
                         Utilities             3,138.74                               
                              Total          $32,888.92                               

               Accordingly, we sustain respondent's disallowance of the               
          duplicated expenses.                                                        
               B.  Personal Allocation of Expenses                                    
                    (1) Utilities                                                     
               During 1990, petitioners utilized 50 percent of their                  
          residence located in New Jersey for personal use and allocated 50           
          percent of the use to petitioner's Schedule C locksmith business.           
          On the Schedule C for the business $9,099 was deducted for                  
          utilities.  Of that amount $3,138.74 claimed for utilities was              
          duplicated.  Of the remaining amount of utilities deducted,                 
          $1,158.26 was attributable to utilities for petitioners' personal           
          residence.  Because petitioner used the residence 50 percent for            
          his business, only $579.13 is deductible on Schedule C.  The                
          other $579.13 is a nondeductible personal expenditure.  Sec. 262.           
          Petitioners presented no evidence that respondent's calculation             
          of the portion of the utilities attributable to personal use was            
          incorrect.  Therefore, respondent is sustained as to this                   
          adjustment.                                                                 
                    (2)  Insurance                                                    
               According to petitioners' Federal income tax return,                   
          petitioner used a van 100 percent for business use and a vehicle            
          56 percent for business use.  On Schedule C the amount of $3,632            




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