Tae M. Kim and Young J. Kim - Page 7




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          address this evidence, infra, as it relates to each of the                  
          claimed expenses.                                                           
          Advertising for 1993 and 1994                                               
               We find that petitioners have established that petitioner              
          paid $403.67 for flyers, cards, envelopes, and stamps during 1993           
          to promote ADE.  Respondent allowed the claimed advertising                 
          expense deduction for 1994.  We hold that petitioners are                   
          entitled to deductions for advertising expenses for 1993 and 1994           
          in the amounts of $404 and $208, respectively.                              
          Car & Truck for 1993 and 1994                                               
               The nature of ADE's business required petitioner to travel             
          frequently to the offices of real estate agents and to                      
          contracting sites.  We find that petitioners have substantiated             
          28,715 business miles for 1993 and 24,520 business miles for                
          1994.  At the business standard mileage rates of 28 and 29 cents            
          per mile, petitioners are entitled to business mileage expenses             
          for 1993 and 1994 of $8,040.20 and $7,110.80, respectively.  See            
          Rev. Proc. 93-51, sec. 5.01, 1993-2 C.B. 593, 594; Rev. Proc. 92-           
          104, sec. 5.01, 1992-2 C.B. 583, 585.  We also find that                    
          petitioners have substantiated petitioner's claimed expenses for            
          tolls and parking for 1993 and 1994.  We hold that petitioners              




          2(...continued)                                                             
          respondent that his request was granted.                                    




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