- 7 -
claim did State Farm deny liability for that claim, although it
did dispute that it was liable as the insurer of Mr. Mitic’s
Mercedes for the amount demanded by Mr. Perez on behalf of
petitioners. The November-December 1994 edition of Kelley Blue
Book suggested a retail value of $42,560 for a 1989 Mercedes-Benz
560 SEL with under 40,000 miles.
Claimed Depreciation Deduction
Petitioners purchased a 1993 Geo automobile (Geo) from their
son in return for a check dated December 8, 1994, that they
issued to him. On December 20, 1994, title to that automobile
was registered in the names of Mr. Mitic and Ms. Mitic. Peti-
tioners kept no mileage log, calendar, or other documentation
regarding their use of the Geo in 1994.
Petitioners’ Returns for the Years at Issue
Petitioners filed a joint Form 1040, U.S. Individual Income
Tax Return (joint return), for each of the years 1993 and 1994.
In each of those joint returns, Mr. Mitic listed his occupation
as “Accountant”. In the 1993 joint return, Ms. Mitic listed her
occupation as “Accountant”, and in the 1994 joint return, she
listed her occupation as “S.E. interior design”. Mr. Mitic
signed the 1993 and 1994 joint returns on February 1, 1994, and
February 3, 1995, respectively. Ms. Mitic signed the 1994 joint
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011