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salaries and wages in 1974 and 1976 are not deductible by
petitioner. I.J. Zand was a Diesel Power employee.
Consequently, the salaries and wages paid to him are not
deductible by petitioner because he has not established his
business purpose for the amounts paid to his brother or that the
expenses were not those of Diesel Power.
G. Office Expenses
Respondent disallowed various office expenses claimed for
the years 1973 through 1978. The issues are factual and many of
the amounts are small. Our findings are dispositive of the items
involved. We will comment only on the larger items; i.e., office
furniture and equipment, an Ohio Bell telephone expense, and
condominium rent.
The expense claimed in 1973 for office furniture in the
amount of $1,498.49 is a duplication of business assets
depreciated by petitioner. The depreciation schedule attached to
his 1973 tax return shows the acquisition in 1973 of furniture in
the amount of $296.25 and a desk in the amount of $1,202.24.
These two items total $1,498.49, the same amount petitioner tried
to expense as office furniture. The deduction is disallowed.
For the year 1974 respondent capitalized office furniture
purchases which totaled $4,020.41. The individual items are set
forth in the depreciation schedule attached to the notice of
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