Lee D. and Marjorie L. Hustead - Page 6

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               Schedule C Expense            1991           1992                      
               Commissions1                  $3,239.75      $1,231.90                 
               Legal & professional service  4,800.00       4,111.59                  
               Office                        3,759.65       3,798.43                  
               Repairs                       295.74         - 0 -                     
               Supplies                      630.88         - 0 -                     
               Taxes                         1,793.94       2,008.31                  
               Travel                        315.00         310.35                    
               Utilities                     253.93         302.70                    
               Other expenses                957.93         389.31                    
               Depreciation                  1,735.18       2,776.28                  
               Insurance                     141.00         141.00                    
               Interest                      9,504.89       7,366.99                  
                    TOTAL                    27,428.54      22,436.86                 
               1 These represent fees paid to Skippack Township as costs              
               for the public hearings.                                               
               All of the above expenses were incurred attendant to                   
          petitioners' business as LM Development and, with one exception,            
          see infra pp. 11-12, were directly related to petitioners'                  
          attempt to improve the value of the land.                                   
          Respondent's Determinations                                                 
               Respondent issued the notices of deficiency for the taxable            
          years 1991 and 1992 on January 6, 1995.  The adjustments to                 
          income were as follows:                                                     
                    Item                          1991           1992                 
               All Schedule C expenses            $27,428        $22,437              
               Self-employment Tax deductions     (8)            (42)                 
               Itemized deductions                (1,309)        (870)                
          Previous Litigation                                                         
               Hustead v. Commissioner, T.C. Memo. 1994-374, concerned the            
          deductibility of petitioners' Schedule C expenses for LM                    






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