Keith F. Marason - Page 15

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               Respondent disallowed the following amounts in 1989:                   
                    Item                          Amount                              
               Parking at 770 California Street   $1,950                              
               (petitioner's residence)                                               
               50 percent of car rental           1,500                               
               payments to J. Clare                                                   
               50 percent of Avis Rental          617                                 
               Car payments                                                           
               Parking tickets                    63                                  
               50 percent DMV renewals            115                                 
               and miscellaneous                                                      
               Amtrak                             373                                 
               Porsche auto invoices              7,311                               
               Total                              11,929                              

               Respondent disallowed the following amounts in 1990:                   

                    Item                          Amount                              
               Rod McClintock                     $2,600                              
               Ray Johnson                        200                                 
               Perl's Body Shop                   647                                 
               S&D Towing                         73                                  
               50 percent of car rental           450                                 
               payments to J. Clare                                                   
               Non-itemized amounts               4,236                               
               Total                              8,206                               
               As to the 1989 and 1990 expenditures related to travel,                
          respondent either disallowed the entire amount in some cases,               
          disallowed 50 percent of them in other cases, and required                  
          capitalization of the full amount of the rest.  With regard to              
          those required to be capitalized, respondent allowed depreciation           
          on 50 percent of the capitalized amounts.                                   
               We generally agree with respondent's determination.                    
          Petitioner testified that he received an estimate that convinced            
          him that merely to paint the car, and return it to the condition            





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