Umit Tarakci - Page 28




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          to establish the periods of ownership with respect to the rental            
          equipment.  Petitioner does not argue that the transportation and           
          storage expenses were related to the consulting services or                 
          portable clean room.  Accordingly, petitioner is not entitled to            
          deduct the equipment transportation and storage expenses.                   
               E.   Office                                                            
               Petitioner claimed deductions of $108 for professional                 
          publications and $241 for copying, printing, and postage                    
          expenses.  As support for the professional publications                     
          deduction, petitioner submitted the business expense account                
          records of Cilena for 1993, showing the $108 in publication                 
          expenses, and testified as to the nature of the publications.  We           
          hold that these expenses are properly deductible as ordinary and            
          necessary expenses.                                                         
               Petitioner testified that the other office expenses related            
          to the general activities of Cilena and the dissolution of                  
          Aeternum.  Petitioner presented the expense account records of              
          Cilena to support the amounts claimed.  Based on the evidence in            
          the record, petitioner has established entitlement to the                   
          deduction of $241 for the other office expenses.                            
               F.   Telephone                                                         
               Petitioner claimed a deduction of $733 for business                    
          telephone expenses, including the use of a cellular phone.                  
          Respondent does not challenge the amount or that petitioner made            






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