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Commissioner, T.C. Memo. 1999-250. Mr. Ngo has not introduced
evidence supporting a deduction in excess of that determined by
respondent for 1995. Accordingly, respondent is sustained on
this issue for 1995.
In regards to 1997, Mr. Ngo’s business ledger reflects
$11,448.63 in legal and professional fees incurred during 1997.
After review of the business ledger, we find that $6,269.43 was
not legal in nature, but instead pertained to various
professional fees including window service and electrician fees.
Accordingly, these amounts are not allowed as legal and
professional fees.6 Additionally, of the $5,179.20 balance, $300
was paid to K.B. for accounting fees and $4,879.20 was paid to
Clement Law Center. Mr. Ngo did not testify as to the purpose of
services rendered by Clement Law Center. We also find that Mr.
Ngo has failed to show that the claimed legal expenses of
$4,879.20 were incurred in carrying on his or Donut Star’s trade
or business. Accordingly, Mr. Ngo is entitled to $300 in legal
and professional fees for 1997.
4. Repair/Maintenance
Mr. Ngo claimed repair/maintenance deductions of $315 and
$15,860 for 1995 and 1996, respectively. Respondent disallowed
these claimed deductions.
Mr. Ngo’s business ledger shows a total of $6,684.36 for
6 See infra Repairs and Maintenance.
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