Umit Tarakci - Page 27




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          the rental equipment at the time the trips occurred.                        
          Additionally, petitioner has not argued that the trips were                 
          related to the consulting services or portable clean room.                  
          Accordingly, we hold that petitioner has failed to prove                    
          entitlement to this deduction.                                              
               Petitioner claimed a deduction of $160 for business meals.             
          However, petitioner concedes that he is entitled only to a                  
          deduction of $36, relating to one business lunch.15  The only               
          evidence presented by petitioner is a reference in the expense              
          account records of Cilena to a “technician lunch”.  Petitioner’s            
          failure to present more evidence as to the business aspect of               
          this lunch precludes entitlement to the deduction.                          
               D.   Equipment Transportation and Storage                              
               Petitioner claimed deductions of $5,326 in equipment storage           
          expenses and $3,66916 in equipment transportation costs.  The               
          storage and equipment transportation expenses are deductible if             
          they are ordinary and necessary in carrying on petitioner’s trade           
          or business activities.  See sec. 162(a).  Petitioner has failed            



               15Petitioner testified that other deducted meals were not              
          related to his business activities and contended that such meals            
          would properly be deductible on Schedule A, Itemized Deductions,            
          as job search expenses.  Petitioner failed to provide any                   
          computations or other evidence to support this contention.                  
               16Petitioner concedes that $1,799.50 in equipment                      
          transportation expenses was not paid until a subsequent year.               
          Accordingly, the equipment transportation expense at issue is               
          $1,869.20.                                                                  





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