Paul M. and June S. Sengpiehl - Page 13

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          are treated as personal expenses for the purposes of section                
          262(a).                                                                     
               Petitioners argue that the telephone expenses are deductible           
          as business expenses under section 162(a), and therefore the                
          deduction of such expenses is otherwise expressly provided.                 
          Petitioners ignore the explicit language of section 262(b).                 
          Petitioners failed to offer any testimony or evidence as to                 
          whether the telephone expenses claimed include long distance                
          charges for business purposes.  Thus, petitioners have failed to            
          establish that they are entitled to a deduction for telephone               
          expense.  Respondent is sustained on this issue.                            
               C.  Other Expenses                                                     
               Petitioner testified that he incurred checking account fees            
          during 1991.  Petitioners did not argue that they are entitled to           
          a deduction for these fees in either of their posttrial briefs.             
          Moreover, petitioners have not established that the amount of               
          fees paid or that the fees were incurred for business purposes.             
          Petitioners are not entitled to a deduction for any checking                
          account fees.                                                               














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