- 26 -
newspapers. The cost of a “daily newspaper of general
circulation is inherently a nondeductible personal expenditure”,
Wheeler v. Commissioner, T.C. Memo. 1984-425 (quoting Wallendal
v. Commissioner, 31 T.C. 1249, 1252 (1959)), so we disallow these
amounts. We also disallowed the $120 for subscriptions to PC
World, PC Magazine, and Byte. Petitioner has not demonstrated to
our satisfaction that his purchase of these magazines had a
business purpose. Thus, the only deductions that we allow in
this category are the $97 he spent to subscribe to Poetry and
Gramophone.
15. Copy Services
As indicated in the notice of deficiency, respondent
originally allowed petitioner’s deduction in the amount of $586
for copy services. While petitioner has submitted documentation
of copy expenses of only $213.95,25 it is quite reasonable for a
document intensive activity such as writing and research to incur
significant copy expenses, and we see no reason to depart from
respondent’s original allowance.
C. Is Petitioner Subject to Penalties Under Sec. 6662?
“I said ‘Interest and penalties? Isn’t that kind of
Overkill? I mean: Hey--I get it!’”
Kornbluth, supra.
25 The assertion that petitioner submitted this number
warrants clarification; there is an amount of $169.43 entered on
the bottom line of a page in his submission with the words “copy
services” handwritten at the top. When combined with a $44.52
item in the “supplies” category that is listed as “photocopies”
a total of $213.95 results.
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