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Intl. Artists, Ltd. v. Commissioner, 55 T.C. 94, 104 (1970);
Sanitary Farms Dairy, Inc. v. Commissioner, 25 T.C. 463, 467-468
(1955); Rodgers Dairy Co. v. Commissioner, 14 T.C. 66, 73 (1950).
Conversely, if an expenditure is primarily motivated by personal
considerations, no deduction for it will be allowed. Henry v.
Commissioner, supra; Larrabee v. Commissioner, supra.
1. Payments in Lieu of Wages
In lieu of wages, Beck's Liquors paid the real estate taxes
on the condominium in which Michael resided, the insurance on the
Topaz, and the premium on Michael's life insurance policy. For
the occasional work Michelle performed for the store, Beck's
Liquors paid for the insurance on the Buick she drove. Those
payments are for services rendered and are deductible by the
corporation.
2. Vehicle Expenses and Depreciation
Section 167 generally allows a depreciation deduction with
respect to property used in a trade or business or held for the
production of income. In determining whether such a deduction is
permitted, courts ordinarily have focused on whether the
acquisition and/or maintenance of property was primarily
associated with profit-motivated purposes. Intl. Artists, Ltd.
v. Commissioner, supra.
On the 1991, 1992, and 1993 corporate returns, Beck's
Liquors claimed vehicle expenses for three vehicles: The pickup
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