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that, as of September 1994, primarily because of marital
difficulties, he had no reason to return to Florida.
Petitioner claimed a deduction for rent in the amount of
$10,710 on account of the reimbursement of Norman for expenses
incurred from April 22, 1994, through September 30, 1994, as
follows (the Florida expenses):
$8,732.50 rent for April-September and application fee
97.12 phone
150.00 home inspection
513.40 utilities
1,202.50 furniture storage
310,695.52 Total
2. Arguments of the Parties
Petitioner argues that the Florida expenses relate to the
relocation of its corporate office from the Dallas apartment to
Florida in April 1994 and the continued use of a home in Florida
as a corporate office for the balance of the 1994 tax year. In
support of that argument, petitioner states: There were many
large Government contractors within a 200-mile radius of Naples,
Florida; its Texas client base was diminishing; and it was able
to secure a large client (Honeywell Corp.) shortly after the
Duquettes arrived in Florida. Petitioner points to a resolution
of the board deciding to relocate the corporate headquarters from
Texas to Florida. Respondent asks us to find that the relocation
3 The sum of the stipulated individual items is $10,695.52.
There is no explanation of the $14.48 difference between this
number and the stipulated total expenses of $10,710.
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