-15-
for the month of August 1993;5 and (3) rent for 14 weeks in the
weekly amount of $43 paid to Red Lion (i.e., $612).6
Petitioners presented limited records to substantiate the
claimed deduction. Nevertheless, insofar as the Port lease is
concerned, the record establishes that petitioners are entitled
to deduct rent for the 7-� month period that the lease was in
effect during 1993; i.e., on or about May 15 through December 31,
1993. In contrast, respondent has allowed a rent deduction for
the period June 1 through December 31, 1993. Accordingly, we
hold that petitioners are entitled to deduct an additional $150
for the first one-half month of the lease term.
Petitioners contend that the $900 security deposit paid to
the Port upon execution of the lease in 1993 is deductible in
that year. We disagree. A security deposit is not deductible,
if at all, until the year actually forfeited. Accordingly, the
$900 security deposit is not deductible in 1993 because it was
not forfeited in that year, but remained refundable upon
termination of the lease.
Insofar as the Red Lion is concerned, petitioners presented
only 14 weekly receipts. However, petitioners presented at least
one receipt for each month of 1993, except November and December.
5 Respondent accepted petitioner's statement that the Port
rebated a portion of petitioner's rent for the month of August
1993.
6 Respondent allowed the latter amount based on the 14
weekly rent receipts from the Red Lion that petitioners produced.
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