Bernardus A. P. Dobbe and Klazina W. Dobbe - Page 2




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          for the taxable year 1993.  Respondent also determined a                    
          deficiency in the Federal income tax of petitioner Holland                  
          America Bulb Farms, Inc. (Holland America), of $35,304 for its              
          fiscal year ended September 30, 1993 (FYE 1993).  Petitioners               
          filed separate petitions contesting respondent’s determinations.            
          Because these cases present common issues of fact and law, they             
          were consolidated for trial, briefing, and opinion pursuant to              
          Rule 141(a).1                                                               
               After concessions,2 the issues for decision are:                       
               (1) Whether Holland America is entitled to deduct the                  
          following expenses as ordinary and necessary business expenses              
          under section 162(a):  (a) $35,296 in landscaping expenses, (b)             
          $34,246 in grocery expenses reimbursed to Mr. and Mrs. Dobbe, (c)           
          $12,203 for the construction of a new solarium attached to Mr.              
          and Mrs. Dobbe’s residence, (d) miscellaneous expenses claimed              



               1All section references are to the Internal Revenue Code in            
          effect for the years in issue, and all Rule references are to the           
          Tax Court Rules of Practice and Procedure.  Monetary amounts are            
          rounded to the nearest dollar.                                              
               2In the notice of deficiency, respondent disallowed a                  
          deduction of $3,926 by Holland America for a telephone system.              
          Before trial, the parties agreed that Holland America’s                     
          expenditure of $3,926 will be treated as a capital expense and              
          that Holland America will be allowed depreciation deductions                
          under secs. 167 and 168 using MACRS guidelines and a 7-year                 
          recovery period.  Accordingly, Holland America’s taxable income             
          for FYE 1993 is increased $3,926 to reflect Holland America’s               
          concession concerning the deductibility of the expense under sec.           
          162(a) and decreased $982 to reflect the depreciation deduction             
          conceded by respondent.                                                     





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