Tae M. Kim and Young J. Kim - Page 3




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          certain deductions.  Petitioner wife was employed by the Federal            
          National Mortgage Association as an analyst during 1993 and 1994.           
               The first issue for decision is whether petitioners are                
          entitled to trade or business expense deductions for 1993 and               
          1994 in excess of the amounts allowed and conceded by respondent.           
               On a Schedule C attached to petitioners' 1993 return,                  
          petitioner reported gross income in the amount of $900 and                  
          claimed expenses in the total amount of $21,642.46 with respect             
          to ADE.  In the statutory notice of deficiency, respondent                  
          disallowed any deductions for the claimed expenses.  After                  
          concessions by respondent, the following amounts remain in issue:           
          Expense                     Claimed   Concessions   In Issue                
               Advertising         $420.00        - 0 -     $420.00                   
               Car & truck         9,504.00       - 0 -      9,504.00                 
               Depreciation        - 0 -          521.85    - 0 -                     
               Insurance           829.40         - 0 -     829.40                    
               Interest            - 0 -          528.09    - 0 -                     
               Legal services      295.00         - 0 -     295.00                    
               Office expense      1,487.22       100.01    1,387.21                  
               Rent or lease of                                                       
               business property    936.00        383.13    552.87                    
               Repairs             3,200.00       - 0 -     3,200.00                  
               Supplies            490.84         32.15     458.69                    
               Taxes & licenses    280.00         976.89    - 0 -                     
               Travel              1,560.00       - 0 -     1,560.00                  
               Meals & entertainment   960.00     - 0 -     960.00                    
               Utilities      1,680.00            351.67    1,328.33                  
               In addition to the amounts claimed on the 1993 Schedule C,             
          petitioners claimed Schedule A employee business expenses for               
          1993 in the total amount of $3,324, listed as follows:                      








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