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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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