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claimed depreciation on a desk with a basis of $1,202.24 and on
furniture with a basis of $296.25. These furniture costs were
not an ordinary and necessary business expenses. Instead, they
were capital expenses.
In 1974 petitioner acquired a Morgan desk costing $592.28, a
Lazarus office machine costing $258.76, a Morgan desk costing
$954.97, an IBM typewriter costing $696, and telephone equipment
costing $1,518.40. He deducted these items on his 1974 return.
They were not ordinary and necessary business expenses; they were
capital expenses.
For the years 1975 and 1976 petitioner claimed deductions
for office furniture and equipment in the amounts of $16,873.59
and $4,407.96, respectively. There is no evidence in the record
regarding these expenditures. In the notice of deficiency for
the years 1975 and 1976 respondent capitalized various items of
office furniture and equipment, and these amounts were set forth
in the depreciation schedule attached to the notice. These
expenditures were not ordinary and necessary business expenses
but were capital expenditures.
In 1973 petitioner purchased briefcases from Albanese in the
amount of $1,500 and Bruni in the amount of $350 that were given
to various Iranians. He deducted these purchases. He also
claimed a deduction in 1973 for Christmas gifts in the amount of
$404.80. There is no evidence in the record regarding the
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