Tae M. Kim and Young J. Kim - Page 9




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          total amount of $1,315.41.  We hold that petitioners are entitled           
          to depreciation deductions for 1993 and 1994 in the total amounts           
          of $522 and $6,810, respectively.                                           
          Insurance for 1993 and 1994                                                 
               Petitioners claimed insurance expense deductions for 1993              
          and 1994 for amounts paid for their automobile insurance                    
          policies.  However, petitioners claimed and we have held that               
          they are entitled to deductions for car and truck expenses based            
          on the business standard mileage rates for 1993 and 1994, which             
          are claimed in lieu of operating and fixed costs such as                    
          gasoline, oil, depreciation, maintenance and repairs, insurance,            
          and registration fees.  See Rev. Proc. 93-51, sec. 5.03, 1993-2             
          C.B. 593, 594; Rev. Proc. 92-104, sec. 5.03, 1992-2 C.B. 583,               
          585.  Accordingly, we hold that petitioners are not entitled to             
          any insurance expense deductions for 1993 and 1994.                         
          Interest for 1993 and 1994                                                  
               The parties stipulated that petitioners are entitled to                
          deductions for interest paid during 1993 and 1994 on amounts                
          borrowed to purchase the condominium unit.  Petitioners presented           
          no evidence that they paid any deductible business interest                 
          during 1993 and 1994 other than the stipulated amounts.  We hold            
          that petitioners are entitled to interest expense deductions for            
          1993 and 1994 in the amounts of $528 and $4,529, respectively.              








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