Bernardus A. P. Dobbe and Klazina W. Dobbe - Page 24




                                       - 24 -                                         
          uphold respondent’s determination disallowing the entire $34,246            
          deduction.                                                                  
               D.  Solarium (“Small Tools” Expense)                                   
               Holland America spent $12,203 to construct a new solarium              
          attached to the Dobbe residence and deducted the entire cost of             
          the new solarium as a “small tools” expense.  Petitioners argue             
          that the new solarium was used solely for business purposes in              
          the year the deduction was taken and that Holland America greatly           
          benefited from the construction of the new solarium because the             
          expense enabled it to experiment with and develop a new product,            
          the medicinal herb Echinacea.  Thus, petitioners contend, the               
          expense properly was deductible under section 162(a) or, in the             
          alternative, the new solarium was deductible as an experimental             
          procedure under section 174(a).  Respondent contends the new                
          solarium benefited Mr. and Mrs. Dobbe personally and added value            
          to their home; therefore, the new solarium was primarily a                  




















Page:  Previous  14  15  16  17  18  19  20  21  22  23  24  25  26  27  28  29  30  31  32  33  Next

Last modified: May 25, 2011