Tae M. Kim and Young J. Kim - Page 11




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          owners' association fees, which are more accurately described and           
          deducted as commissions and fees.  We therefore hold that                   
          petitioners are not entitled to any deductions for 1993 and 1994            
          for the rental or lease of business property.  In accordance with           
          the parties' stipulations, we hold that petitioners are entitled            
          to deductions for 1993 and 1994 for commissions and fees in the             
          amounts of $383 and $2,815, respectively.                                   
          Repairs & Maintenance for 1993 and 1994                                     
               We find that petitioners paid for a number of repairs to               
          petitioner's home office during 1993 and 1994.  After examining             
          the records of the costs of such repairs, we hold that                      
          petitioners are entitled to deductions for 1993 and 1994 for                
          repairs and maintenance in the total amounts of $2,087 and                  
          $1,168, respectively.                                                       
          Supplies for 1993 and 1994                                                  
               For 1993 and 1994, petitioners claimed deductions for                  
          supplies in the amounts of $490.84 and $250.18, respectively.               
          Respondent conceded $32.15 of the amount claimed for 1993.  We              
          find petitioners' records of the supplies purchased during 1993             
          and 1994 reliable.  We hold that petitioners are entitled to                
          deductions for 1993 and 1994 for supplies in the total amounts of           
          $491 and $250, respectively.                                                









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