Mahendra K. Tandon - Page 17

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               Petitioner claimed leasing expenses in the amounts of                  
          $4,474.37, $8,123.40, and $12,853.67 in 1985, 1986, and 1987,               
          respectively, for the 1984 Cadillac and the Rolls Royce.                    
          Respondent disallowed these deductions.                                     
               The leasing expenses relate to the 1984 Cadillac and the               
          Rolls Royce.  Petitioner's sister testified that the Rolls Royce            
          had very low mileage and was usually in the garage.  Petitioner             
          did not testify, and presented no evidence, regarding the                   
          business use of the Rolls Royce.  The mileage logs petitioner               
          submitted supposedly relate to the business use of the 1984                 
          Cadillac; however, as we stated earlier, we do not rely on those            
          logs.  Petitioner has not established that he used the 1984                 
          Cadillac or the Rolls Royce in his business; therefore, we                  
          conclude that petitioner is not entitled to deductions for                  
          leasing expenses in 1985, 1986, or 1987.7                                   
                    3.   Car and Truck Expenses                                       
               On his 1985 and 1986 tax returns, petitioner claimed car and           
          truck expenses of $1,642.34 and $1,279, respectively.  Respondent           
          disallowed these deductions.                                                
               Petitioner testified that the car and truck expense                    
          deductions he claimed were for his annual expenses for gasoline.            
          There is, however, no evidence in the record regarding the amount           

               7  We note that petitioner attempted to claim both                     
          depreciation deductions and lease expense deductions on the Rolls           

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