Gerald L. and Joy M. Zeidler - Page 16

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               Based on the evidence presented at trial, the Court is                 
          satisfied that petitioners did not use the questioned property as           
          a residence for each of the years at issue for periods that would           
          exceed the time periods set out in section 280A(d)(1).  Although            
          petitioners made several visits to the property during the years            
          in question and, on one or two occasions used the property as a             
          residence well under the 14-day/10 percent standard, the visits             
          to the property were essentially for maintenance.  The Court,               
          therefore, sustains petitioners on this issue, that section                 
          280A(c)(5) does not preclude petitioners from claiming losses               
          from this property in excess of the rentals therefrom.                      
               Respondent's alternative adjustment to petitioners'                    
          deductions from rental activities relates to the 1991 tax year on           
          the same property discussed above, as to which $313 expenses for            
          supplies, $596 for meals, and $1,059 for automobile travel were             
          disallowed for lack of substantiation.  On this record, the Court           
          sustains respondent as to the three items.  Petitioners presented           
          no proof, such as bills, receipts, or canceled checks, to                   
          establish that they incurred the $313 expense for supplies.  As             
          to the automobile and meal expenses, records for these expenses             
          were also not produced.  Section 162(a) allows a deduction for              
          all ordinary and necessary expenses paid or incurred during the             
          taxable year in carrying on any trade or business, including,               
          under section 162(a)(2), "traveling expenses (including amounts             

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