Robert W. Tschetter - Page 21

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          including the farmhouse.  One of the business activities of Wolf            
          Creek Farm was the leasing of the homestead, including the                  
          farmhouse.  Thus, the farmhouse is property used in the                     
          corporation’s trade or business.                                            
               We hold that Wolf Creek Farm is entitled to a deduction for            
          depreciation of the farmhouse for each of the years at issue as             
          claimed.                                                                    
                    d.   Taxes                                                        
               Wolf Creek Farm deducted property taxes of $257 in 1995,               
          $208 in 1996, and $190 in 1997 attributable to the farmhouse.               
          Wolf Creek Farm owned the homestead.  Section 164(a)(1) allows              
          the owner of property a deduction for real property taxes                   
          regardless of whether they are paid or incurred in a trade or               
          business.  We hold, therefore, that Wolf Creek Farm may deduct              
          property taxes as claimed in the years at issue.                            
                    e.   Summary of Food and Lodging Expenses                         
               To summarize, Wolf Creek Farm may deduct the following                 
          expenses for the years at issue:                                            
                                         11/30/95     11/30/96 11/30/97               
          Property tax--house               $257         $208     $190                
          Property insurance--house          667          631       -–                
          Depreciation--house              569          587       575                 
          Total                            1,493        1,426    765                  
               Wolf Creek Farm may not deduct the following food and                  
          lodging expenses:                                                           






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