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Petitioner has failed to prove that the $114 in dispute related
to advertisement of the Harwichport property. We sustain
respondent's disallowance of these items.
Respondent disallowed a $486 deduction for the overhaul of a
clock. Petitioner offered no evidence relating this item to the
Harwichport property. We sustain respondent's disallowance of
this item.
Respondent disallowed a $322 deduction for the rental of a
Ryder truck. Petitioner used the Ryder truck to deliver new
appliances to the Harwichport property. We find that the $322
truck rental expense must be capitalized as a preopening expense
as discussed below.
Real Estate License
Respondent disallowed the costs associated with the renewal
of petitioner's Connecticut real estate license. We find no
connection between petitioner's real estate license and his
activity on the Harwichport property. We sustain respondent's
disallowance of these items.
Taxes
Respondent disallowed a $126 payment to the Town of Warren
for personal property tax on the value of the Lincoln; a $10
payment to the Wallingford Tax Office; and a $248 payment listed
under "90' Cap. Exp." Petitioner is entitled to deduct personal
property taxes associated with the Lincoln pursuant to section
164(a)(2). Petitioner offered no explanation for the $10 payment
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