William W. Halle IV, and Janice C. Halle - Page 19

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          was deducted for insurance.  Of that amount $1,327.26 was                   
          duplicated.  The remaining amount of insurance, after subtracting           
          the duplication, was attributable to insurance on petitioners'              
          two vehicles, one being used exclusively for the Schedule C                 
          business and the other one being used 56 percent for business               
          use.  The portion of the insurance attributable to the personal             
          use of one of petitioners' vehicles is not deductible because it            
          is a nondeductible personal expenditure.  Respondent determined             
          that the portion of the insurance expense attributable to                   
          personal use was $507.10.  Petitioners presented no evidence that           
          respondent's calculation was incorrect.  Therefore, respondent is           
          sustained as to this adjustment.                                            
                    (3) Car and Truck Expense                                         
               On Schedule C petitioners deducted car and truck expenses in           
          the amount of $8,280 of which $1,076.64 was duplicated and $2,301           
          was a payment for the lease of a Chevrolet van.  The remaining              
          expenses of $4,902.36 deducted on Schedule C were not allocated             
          by petitioners between business and personal use, even though one           
          of the vehicles was used 44 percent for personal use.                       
          Petitioners should have allocated the expenses between business             
          and personal use.  Consequently, they are not entitled to deduct            
          expenses of $1,078.52, the amount allocated by respondent to                
          personal use of one of the vehicles.                                        








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