Bernardus A. P. Dobbe and Klazina W. Dobbe - Page 27




                                       - 27 -                                         
               Respondent contends that the miscellaneous expenses                    
          attributable to the Dobbe residence were nondeductible personal             
          expenses of Mr. and Mrs. Dobbe and that Holland America conferred           
          an economic benefit on Mr. and Mrs. Dobbe by paying those                   
          expenses.  Petitioners argue the miscellaneous deductions were              
          ordinary and necessary business expenses because Holland America            
          leased the entire farm, including the residence, for business               
          purposes.  We agree with respondent that Holland America is not             
          entitled to deduct the expenses attributable to Mr. and Mrs.                
          Dobbe’s residence.                                                          
               The expenses of maintaining a household, including                     
          utilities, insurance premiums, and property tax, are personal               
          living expenses and are not deductible.  See sec. 262(a); sec.              
          1.262-1(b)(2) and (3), Income Tax Regs.  As we held earlier in              
          this opinion, the residence was not leased to Holland America               
          and, with the exception of the office, was not used for business            
          purposes.  Because the miscellaneous expenses were personal and             
          were unrelated to the business of Holland America, we sustain               
          respondent’s determination that the above amounts are not                   
          deductible as ordinary and necessary business expenses.                     
               F.  Golf Clubs (“Customer Relations” Expense)                          
               Holland America claimed a deduction of $1,455, which it                
          spent to purchase a set of golf clubs for Rinus Heemskerk, a                
          flower bulb salesman/broker in The Netherlands.  Holland America            






Page:  Previous  17  18  19  20  21  22  23  24  25  26  27  28  29  30  31  32  33  34  35  36  Next

Last modified: May 25, 2011