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