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Petitioner alleges that the remaining $1,412.59 of
miscellaneous deposits are not includable in gross income.
Petitioner claims the deposits are from the following sources:
Party expenses; Southern States store refund; Winnebago
Industries stock dividends; repayment of gift from brother; cash
ATM redeposit; Pagenet phone rebate; Catherine Douglas loan
repayment; Farm Credit crop refund; and reimbursement for gift
purchased by mother. Petitioner provided copies of checks
received and deposited into the account that reflect these
payments. We are satisfied that petitioner has provided credible
evidence establishing that these deposits are from nontaxable
sources and are not includable in petitioner’s gross income.
3. Deductions
Petitioner claims that she is entitled to deductions for
expenses for repairs, dues, gifts, insurance, legal and
professional services, outside services, supplies, telephone and
communications, and utilities of $13,279 that were claimed by
Sams, Inc. and disallowed by respondent.
Under section 162(a), a taxpayer may deduct all ordinary and
necessary expenses paid during the taxable year in carrying on
any trade or business. Commissions and insurance expenses paid
are deductible under section 1.162-1(a), Income Tax Regs. The
cost of incidental repairs which neither materially add to the
value of a property nor appreciably prolong its life are
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