Kenneth G. Schladweiler - Page 15

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               We hold that the portion of petitioner’s repair expenses               
          paid in 1994 to repair the damage from the 1994 accident is                 
          deductible under section 162(a).                                            
               Respondent determined that petitioner was entitled to                  
          additional depreciation deductions of $1,630, $2,609, and $4,145            
          in 1992, 1993, and 1994, respectively.  The adjustments are                 
          attributable to respondent’s determinations that certain of                 
          petitioner’s repair expenses must be capitalized and depreciated.           
          In view of our holding regarding petitioner’s repair expenses,              
          petitioner’s depreciation deductions for the years in issue must            
          be decreased to reflect respondent’s concessions and our ruling             
          on the deductibility of the 1994 accident repairs to petitioner’s           
               Petitioner claimed a utility expense deduction of $1,429 for           
          1994.  Petitioner lived with his parents when he was not                    
          traveling on business, but he did not pay any rent or contribute            
          on any regular schedule to the family’s household expenses.                 
          Petitioner testified that he occasionally paid his parents’                 
          utility (phone, sewer, and water) bills in order to reimburse               
          them for the additional costs resulting from his use of their               
          electricity, water, and phones for his business.  Petitioner used           
          his parent’s water to wash his trucks.  He used their electricity           

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