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Petitioners deducted car and truck expenses of $8,127 for
1992 and $3,836 for 1993. These expenses related to mileage,
insurance, and repairs for three vehicles. With respect to one
of the vehicles, petitioners also deducted lease payments of
$4,088 for 1992 and $4,088 1993.
Petitioners deducted meal and entertainment expenses of
$6,474 for 1992 and $14,130 for 1993. These expenses included
the cost of personal meals and trips (e.g., a trip to the
amusement park Pixieland), as well as $2,000 for video rentals.
Petitioners deducted repair and maintenance expenses of
$1,079 for 1992 and $56 for 1993. These expenses related to
television repairs, VCR repairs, pool chemicals, lawnmower parts,
and the cost of building a stairwell gate.
Petitioners deducted utility expenses of $4,038 for 1992 and
$4,328 for 1993. These expenses related to cable television,
gas, electricity, telephone service, garbage removal, and water.
Respondent disallowed all of the deductions relating to
legal and professional, rent or lease, supply, and meal and
entertainment expenses. Respondent also disallowed the 1992
deductions for car and truck, repair and maintenance, and utility
expenses, as well as the 1993 deductions for interest and travel
expenses. The deductions disallowed by respondent totaled
$39,818 for 1992 and $52,656 for 1993. Respondent determined
that petitioners were liable for deficiencies of $11,255 for 1992
and $16,342 for 1993. Respondent also determined that for 1993
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