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I. Expenses for Insurance and Dues and Publications
Our findings of fact are dispositive of the expenses
disallowed by respondent for insurance and dues and publications.
It is not necessary to repeat them here.
J. Depreciation
For the years 1973 through 1980 respondent disallowed
depreciation expenses in the amounts of $560.90, $6,820.14,
$6,154.42, $10,902.44, $5,913, $13,652, $7,461, and $7,806.36,
respectively.
For the year 1981 respondent allowed depreciation in an
amount that is $2,494 greater than the amount claimed by
petitioner on his income tax return. Respondent's adjustments to
depreciation take into account items that petitioner expensed on
his income tax returns but that respondent determined were
capital expenditures subject to depreciation.
For the years 1973 and 1976 petitioner offered no evidence
to refute respondent's adjustments to the depreciation claimed.
Therefore, respondent's adjustments are sustained.
For the years 1974 and 1975 respondent disallowed
depreciation claimed on petitioner's apartment in Kitzbuhel,
Austria. Petitioner contends that the apartment was purchased as
a place to stay while in Europe in lieu of hotels. He transacted
business from the apartment, including meeting business
associates and making business-related telephone calls. He, his
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