- 29 - expenses was that his condominium wasn’t “up to snuff” to the point that he was comfortable meeting there with new clients or other clients he wanted to impress. Ms. Toya Turney (Ms. Turney) of the Nashville Electric Service (NES), who was called by respondent, testified, based on the records of NES, that Ms. Push had electrical power activated in her name at 403 South Timber Drive on November 23, 1992. The records of NES further reflected that, up until the trial date of this case on October 26, 1999, Ms. Push’s utility account at 403 South Timber Drive remained active. Finally, Ms. Turney testified that the NES electricity usage records for 403 South Timber Drive indicated that someone was living at that location during each of the years at issue. This testimony contradicts petitioner's testimony that he used this property only 30 to 40 days per year. On this record, the Court finds that the amounts expended by petitioner, during 1994, 1995, and 1996, for the rental of a condominium at 403 South Timber Drive in Nashville were not ordinary and necessary expenses incurred in the conduct of petitioner's trade or business. Thus, the Court holds these expenses are not deductible by petitioners. For 1994, petitioners deducted other expenses of $751.35 for equipment, $147.39 for miscellaneous, and $770 for dues and subscriptions. The equipment expenses consisted of severalPage: Previous 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 Next
Last modified: May 25, 2011