Samuel T. Seawright and Carol A. Seawright - Page 18




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          of less than 1 year are currently deductible, Clemons v.                    
          Commissioner, T.C. Memo. 1979-273, the cost of tools with a                 
          useful life that exceeds 1 year are recovered by depreciation,              
          secs. 167(a) and 168(b).                                                    
               Petitioners offered no evidence about the type, expected               
          useful life, or cost of each tool acquired.  Consequently, we               
          have no basis for determining which costs might be currently                
          deductible or for estimating appropriate depreciation deductions            
          for tools with useful lives greater than 1 year.                            
               Taxes and Licenses                                                     
               On their 1995 return, petitioners claimed a $1,776 deduction           
          for taxes and licenses.  In the notice of deficiency, respondent            
          allowed $1,024.  On the basis of our detailed review of the                 
          record, we find that petitioners are entitled to a deduction of             
          $1,105 for taxes and licenses.                                              
               Utilities                                                              
               On their 1995 return, petitioners claimed a $646 deduction             
          for utilities.  In the notice of deficiency, respondent allowed             
          $404.  Petitioners have not established that they are entitled to           
          a deduction for utilities expenses greater than respondent has              
          allowed.                                                                    
               Cat Food                                                               
               On brief, respondent concedes that petitioners are entitled            
          to a $300 business expense deduction for cat food that                      






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