- 13 -
only half of the receipts should be attributed to each
petitioner.
Respondent disallowed checks to Vincent Morelli,
petitioners' landlord, totaling $951 ($317/mo.) in January,
February, and March of 1982. In later months, a slightly higher
amount was paid to VJ King Enterprises, which respondent did
allow. We conclude that petitioners are entitled to deduct the
$951.00 in addition to the amount of $50,783.10 allowed in
respondent's determination, or a total of $51,734.10 for 1982.
In determining petitioners' 1983 expenses, respondent did
not allow any expenditures from the Indian Rocks account, even
though, after opening that account in July, petitioners rarely
used the Park Bank account. During 1983, petitioners paid
$9,548.61 to Ranco, $17,164.52 to Tecumseh Products, and
$2,756.24 (4 months x $689.06) in rent from the Indian Rocks
account. It is highly likely other allowable business expenses
were among the $106,659.95 paid from the Indian Rocks account
during 1983, but petitioners have not substantiated the purposes
of any further checks from that account. We have added the
foregoing three amounts, totaling $29,469.37, to the $62,709.23
of expenses allowed by respondent, or a total of $92,178.60 for
6(...continued)
status. Thompson v. Commissioner, 78 T.C. 558, 561 (1982);
Roberts v. Commissioner, T.C. Memo. 1996-346.
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