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the portions thereof now deemed by respondent to be allowable or
not allowable. Note that some of the categories of expenses are
different for each year:
1990
Computer Expenses Allowed ByDisallowed By
Category Spreadsheets*Per Return RespondentRespondent
Rent $ 8,220 $ 11,765 $ 1,190 $ 9,855
Utility 3,687 21,279 19,604 1,675
Office 7,079 7,640 1,202 6,438
Wages 77,191 82,299 57,743 24,556
Fines & Losses3,770 3,770 1,623 2,147
Legal 9,232 9,732 744 8,988
Emp. Ben. 0 1,320 414 906
$109,179 $137,805 $82,520 $54,565
* The 1990 spreadsheet totals are based on 11 out of 12 months.
As explained, one month of the 1990 spreadsheets was not put
into evidence.
1991
Computer Expenses Allowed ByDisallowed By
Category Spreadsheet Per Return RespondentRespondent
Home Office $ 0 $ 2,291 $ 0 $ 2,291
Utility 2,115 2,115 1,944 171
Office 4,109 4,109 946 3,163
Wages 81,958 81,958 56,665 25,293
Fines & Losses 4,875 2,689 1,501 1,188
Legal 3,711 3,711 252 3,459
Medical 1,188 1,188 414 774
Travel 2,880 2,880 0 2,880
Meals & Ent. 5,303 4,244 2,582 1,662
$106 ,139 $105,185 $64,304 $40,881
The disallowed portion of the rent, utility, and office
expenses claimed for 1990 and of the utility and office expenses
claimed for 1991 relate to petitioner's home office.
OPINION
Under section 162(a), a taxpayer is permitted to deduct all
ordinary and necessary expenses paid or incurred in carrying on a
trade or business. Under section 280A, however, deductions
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