John Robert Maguire - Page 12

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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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