Carlton H. Perry - Page 4

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          (1) he and Ms. Perry took a total of 10 trips during 1989;                  
          (2) those trips were taken during the months of April through               
          October 1989; (3) each such trip lasted from two to 15 days; and            
          (4) the total number of days that they spent on those trips was             
          70 days.  Petitioner also described in detail in the handwritten            
          log his experiences during such trips, including the places at              
          which he and Ms. Perry camped, the walks and hikes they took, the           
          flowers, plants, and wildlife they saw, an old grave site they              
          visited, the sunrises and the sunsets they watched, and the food            
          they ate.  The handwritten log did not in any way indicate that             
          there was any business purpose for the trips that petitioner and            
          Ms. Perry took in, or for any other use of, the motor home during           
          1989.                                                                       
               In his 1989 return, petitioner reported the following                  
          expenses totaling $17,442 that he claimed were associated with              
          the maintenance of the motor home:                                          
                       Depreciation                         $8,106                    
                       Equipment repairs                       363                    
                       Gas, lube, tune-up                    1,469                    
                       General maintenance and repair        1,669                    
                       Groceries and related items             939                    
                       Household miscellaneous expenses        285                    
                       Insurance                               929                    
                       Interest                              3,682                    
               Petitioner allocated 50 percent of the total reported                  
          expenses of $17,442 to his rental real estate activities and                
          claimed a deduction of $8,721 in Schedule E of his 1989 return              
          for the use of the motor home in connection with those activi-              





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