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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).
Depreciation
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
truck.
Utilities
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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