- 21 -
4. Conclusion
We shall sustain respondent’s determination of a deficiency
to the extent based on a disallowance of a deduction for
reimbursement of the Florida expenses.
D. The Bethesda Apartment Expenses
1. Facts
At the meeting of the board on February 8, 1992, in addition
to resolving that petitioner’s offices be transferred to Texas,
the board resolved:
The corporation will maintain a Corporate apartment in
Maryland to serve as a Resident Agent address as
required by Maryland law. The corporate apartment will
also be used by employees of the Corporation when
traveling to the Washington area on Corporation
business.
On the 1994 tax return, petitioner claimed a deduction with
respect to the Bethesda apartment as follows (the Bethesda
apartment expenses):
$9,540 monthly rent of $795 paid to owner
805 maid service
1,300 cable TV
15 parking fee
43 Pepco
19 newspaper
1,294 telephone
897 answering service
80 misc. credit card charge
413,993 Total
4 Here again there is no explanation of the discrepancy (in
this case, $1) between the sum of the individual items and the
stipulated total of $13,994. Presumably, the $1 was lost in
rounding one or more of the items to the nearest dollar.
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