Barry D. and Suzanne B. Whalley - Page 18

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          direct relationship to the production of business income as                 
          required by section 162.                                                    
               The balance of the 1992 advertising deductions represents              
          amounts paid for raffle tickets and newspaper advertisements.               
          The raffle tickets were a personal expense.  Sec. 262.  With                
          respect to the newspaper advertisements, petitioner asserts that            
          such expenses were incurred to sell his 1989 Chevrolet van,                 
          purportedly used in his business.  Petitioner, however, failed to           
          provide invoices at trial to support the purpose of the checks.             
               Thus, we find that the balance of petitioner's 1991 and 1992           
          claimed advertising expenses is not deductible.                             
               B. Depreciation, Insurance and Other Automobile-Related                
          Expenses                                                                    
               Petitioner claimed depreciation of $4,100 for 1991 based on            
          a $23,300 purchase contract dated June 1989, for a 1989 Chevrolet           
          van.  For 1992, petitioner claimed depreciation of $4,800 based             
          on a sales invoice from an unknown source for a 1993 Ford van               
          purchased for $22,476 in December 1992.  The purchase price was             
          paid in full, and nothing was financed.                                     
               For 1991 and 1992, petitioner claimed insurance expenses of            
          $587 and $545, respectively.  Petitioner claimed 100 percent of             
          the insurance costs for 1991 and 1992 on his Chevrolet van.                 
          Petitioner asserts that the insurance claimed for 1992, which was           
          paid by a check made out to Safeco Insurance Co. is for the Ford            
          van.  However, the automobile policy premium indicates that the             
          insurance coverage is for a 1989 Chevrolet.                                 



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