Norman E. Duquette, Inc. - Page 38




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          for the audit year is $531 determined as follows:  16.7% x                  
          $15,884 (the original cost of the auto) x 20%.                              
          VI.  Supplies                                                               
               On the 1994 tax return, under the heading “Other                       
          Deductions”, petitioner deducted $8,900.50 for “Supplies”                   
          (supplies).  Of that amount, $2,765 remains in dispute.9  The               
          remaining amount claimed for supplies is as follows:                        
                    (1) Safe deposit box          $30                                 
                    (2) Registry of motor vehicles     498                            
                    (3) Condo application fee          100                            
                    (4) Furniture storage              730                            
                    (5) Office decorations             300                            
                    (6) FOIA request              488                                 
               (7) Entertainment                       247                            
                    (8) Auto insurance                 149                            
               (9) Life insurance                      90                             
               (10) Medical bills                    133                              
                                        Total     2,765                               
               Items (1)-(4) represent costs associated with Aline’s                  
          relocation from Dallas to Florida.  We find that petitioner’s               
          payment of those costs, like its payment of other costs                     
          associated with Aline’s relocation, was not in connection with              
          petitioner’s business.                                                      
               Item (5), office decorations, also represents a personal               
          benefit to the Duquettes, based upon our finding, supra sec. II.B           




               9  A portion of this difference is attributable to                     
          petitioner’s concession prior to trial, that many of the                    
          reimbursements for so-called supplies charged to American Express           
          by Norman related to nondeductible personal items.                          





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