- 19 - those repair parts were given to petitioner without consideration or in the form of a loan repayment. Petitioner has not shown that the repair parts were merchandise held for sale to customers in the normal course of its business. Accordingly, respondent’s determination that petitioner’s 1992 beginning inventory was overstated is sustained. Expense Items A. Findings of Fact 1. Equipment Purchase During 1991, petitioner purchased equipment from Traylor Brothers for $22,250 and deducted the cost of the equipment on its 1992 tax return. Respondent determined that petitioner was not entitled to expense the cost of equipment but that the cost should be capitalized and depreciated.7 2. Miscellaneous Expense For its 1992 tax year, petitioner claimed a deduction for miscellaneous expense items in the total amount of $15,204. Respondent determined that petitioner failed to establish that the entire amount was for ordinary and necessary business expenses, disallowing $11,997 of the $15,204 claimed deduction. 7 Petitioner claimed depreciation in the amount of $3,214.29. Respondent, however, determined that the correct depreciation deduction should have been $4,500.16 and made the necessary upward adjustment.Page: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
Last modified: May 25, 2011