- 23 - 3. Automobile Expenses Respondent disallowed automobile and truck expenses for the 1992, 1993, and 1994 tax years of $3,794, $6,177, and $5,925, respectively. Respondent disallowed the above-listed amounts because of petitioner’s failure to substantiate that the amounts were expended for business use of automobiles and trucks. Petitioner did not offer any evidence at trial or present any argument on brief regarding these amounts. Accordingly, respondent’s determination on these items is sustained. 4. Depreciation Deductions For the 1992 and 1993 tax years, petitioner depreciated the full cost of vehicles used by shareholders Bone and Guerrero without taking into consideration their personal use of the vehicles. Petitioner attempted to justify the full amount of depreciation it claimed on the grounds that the vehicles were required to be available on call 24 hours a day. Section 167 allows a deduction for the depreciation of business equipment used in the course of a business or trade. Section 280F, however, reduces the amount of depreciation that can be claimed for passenger automobiles. Specifically, section 280F limits the allowable amount of depreciation to a multiple equal to the percentage of actual business use. See sec. 1.280F- 2T(i), Temporary Income Tax Regs., 49 Fed. Reg. 42707 (Oct. 24, 1984).Page: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 Next
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