- 5 -
Respondent argues that petitioner's claimed rent expense
represents a duplication of his claimed office expense,
previously allowed by respondent.
The amount of office expenses claimed by petitioner and
allowed by respondent, $5,445.55, is greater than the "personal
expenses" in the amount of $4,382.48 indicated in the letter.
Moreover, respondent has allowed petitioner's claims for other
expenses in addition to office expenses. Consequently, we
conclude that petitioner's claimed rent expense represents a
duplication of expenses previously allowed by respondent.2
Petitioners have failed to establish that they are entitled
to the claimed rental expense deduction in the amount of
$3,271.90. Rule 142(a). We, therefore, sustain respondent's
determination on this issue.
(b) Claimed Bad Debt Deduction
On June 2, 1992, petitioner and an associate, Peter
Kostochko, agreed to purchase a dwelling located at 107 Mill
Street, Glastonbury, Connecticut, for $99,000.3 Petitioner paid
2 We are also troubled by a discrepancy between the figures
indicated in the letter and other items in the record. The
amount indicated as "fixed expenses" in the letter, $3,271.90, is
greater than 35 percent of $8,638, the amount of gross
commissions indicated on the Form 1099. Respondent objected to
the admissibility of the letter on the basis of hearsay. While
we have admitted the letter, we have previously concluded that
the claimed expenses are a duplication of other expenses claimed
by petitioner and allowed by respondent.
3 The record does not indicate the precise nature of Mr.
(continued...)
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011