Umit Tarakci - Page 30




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          (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 itemized               






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