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Petitioner's claimed deductions include, inter alia: (1) The
costs related to leasing petitioner's purported home office, a
five-room modular building located on a 5-acre compound, where
petitioner and his wife also resided; (2) all utility costs
associated with the purported home office; (3) the costs
associated with furnishing petitioner's purported home office,
including the costs related to purchasing a television, washing
machine, bed, and hot tub; (4) the cost of purchasing an
insurance policy on petitioner's life; (5) all costs associated
with three cars used by petitioner and members of his family,
including the costs incurred in driving between petitioner's job
location as a military instructor in Sacramento, California, and
his purported home office in Lodi, California; (6) expenses
incurred in traveling to Michigan, where he attended his mother's
funeral; (7) his daughter's dormitory expenses at college; (8)
dental expenses for himself and his family; and, (9) all costs
associated with the telephone in petitioner's home office, which
was the only telephone line in the dwelling.
As indicated in the notice of deficiency, respondent denied
all of petitioner's claimed deductions, with the exception of
expenses for postage and depreciation attributable to the cost of
certain office equipment.4 Respondent determined that the
4 Respondent allowed petitioner deductions for postage in
the amounts of $70 in 1990, $143 in 1991, and $211 in 1992.
Respondent allowed deductions for depreciation expenses in the
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