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donations pursuant to section 1.170A-13(a)(1), Income Tax Regs.,
but she also testified that the wallpaper, interior paint, and
ironing board were given to her mother, which items thus are
personal and nondeductible. Consequently, respondent’s
determination is sustained.
9. Repairs/Maintenance
Petitioner deducted $1,660 for repairs and maintenance in
1993. Of that amount, respondent allowed $197. Petitioner
testified that all of the personal checks written to Tony Lloyd,
Interior/Exterior Decorating Specialists, totaling $849, are for
remodeling her mother’s residence. Since this remodeling is
personal in nature, the expenses are not deductible. Petitioner
argues that the repairs were made in lieu of rent to her mother.
If that were the case, petitioner would have included these
amounts under storage expenses. In any event, we have already
determined that the amounts deducted as rent were for
petitioner’s habitation as opposed to storage use, and thus were
personal in nature.
Since petitioner has not provided any other evidence for
repairs or maintenance, she is not entitled to any deduction in
excess of respondent’s determination.
F. Cost of Goods Sold
1. Wages/Payroll/Outside Services/Cost of Labor
During the years in issue, petitioner used four different
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