- 30 - (1929). Petitioner’s failure to prove the period of ownership with respect to the equipment precludes entitlement to any deduction for the security antitheft costs. Petitioner also claimed a repair and maintenance deduction of $65 for lock services incurred in early April of 1993. Petitioner testified that a lock at the Aeternum facilities was damaged and that he replaced the lock to protect his own investment, not to protect an Aeternum investment. Petitioner’s claimed deduction is for an expense related solely to property which he has not established ownership of. Accordingly, petitioner is not entitled to this deduction. H. Advertising Petitioner claimed a deduction of $126 for advertising expenses related to the sale of equipment owned by Cilena. Advertising expenses are allowed as a deduction under section 162 if the taxpayer can show a sufficient connection between the expenditure and the taxpayer's business. See RJR Nabisco Inc. v. Commissioner, T.C. Memo. 1998-252; sec. 1.162-1(a), Income Tax Regs. To substantiate the advertising deduction, petitioner testified that the expense was related to the selling of equipment and provided respondent with a copy of a Cilena check for $126, payable to “San Jose Mercury News”, dated June 14, 1993. Petitioner also referenced the payment in his itemizedPage: Previous 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 Next
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