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1994 1995 1996 1997 1998
Advertising --- $231 $392$173 $292
Car expenses $1,912 5,472 5,560 6,888 2,621
Commissions/fees 120 382 33 --- ---
Legal/prof. services --- 560 --- --- ---
Office expense --- --- 577 78 133
Supplies 1,162 1,582 --- 1,352 1,684
Travel 605 200 2,574 616 ---
Meals/entertainment1 405 169 194 52 186
Utilities --- 761 836 608 348
Other expenses
Pubs 15 3,289 3,226 --- ---
Seminars/workshops --- 1,196 2,587 1,3641,104
Rally tickets 24 --- --- --- ---
Cell phone --- --- 592 458 1,086
Dues --- --- --- 56 28
Postage --- --- 128 13 11
Voice way --- --- --- --- 314
______ _______ _______ _______ ______
Total expenses 4,243 13,842 16,69911,658 7,807
1Net after 50-percent reduction per sec. 274(n).
For the year in issue, petitioners deducted car expenses for
a Suburban SUV based on “business” use of 74.13 percent.
Petitioners determined this percentage based on the following
figures:
“Business” miles driven 21,867
Personal miles driven 7,633
Total miles driven 29,500
Discussion
Under section 183(a), if an activity is not engaged in for
profit, then no deduction attributable to the activity shall be
allowed except to the extent provided by section 183(b). In
pertinent part, section 183(b) allows deductions to the extent of
gross income derived from an activity that is not engaged in for
profit.
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