Delaware Corp., et al. - Page 33

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          Mitchums Creek property, (7) telephone expenses of $2,700,12                
          (8) child care expenses of $7,762, and (9) depreciation of                  
          $10,909 attributable to the Virginia Beach property.  In Delaware           
          Corporation’s notice, respondent also determined that the 1994              
          claimed rent of $7,200 should not be included in Delaware Corpo-            
          ration’s gross income for 1994.                                             
               In Delaware Corporation’s notice, respondent determined,               
          inter alia, to disallow the following deductions claimed in                 
          Delaware Corporation’s 1995 return:  (1) Real estate taxes of               
          $2,963 attributable to the Virginia Beach property, (2) mortgage            
          loan interest of $11,676 attributable to the Virginia Beach                 
          property,13 (3) utility expenses of $1,777 attributable to the              


               12In Delaware Corporation’s notice, respondent did not show            
          the disallowed portion of the total telephone expense deductions            
          of $2,700 that Delaware Corporation claimed in its 1994 return              
          (1) that was attributable to the Caroline County farm and                   
          (2) that was attributable to the Virginia Beach property.  The              
          record establishes that Delaware Corporation paid during 1994               
          telephone expenses of $312 attributable to the Caroline County              
          farm and $1,682 attributable to the Virginia Beach property.                
          Although the record is not clear regarding the property or                  
          properties to which the remaining expenses of $706 are attribut-            
          able, the parties do not dispute that for 1994 the total tele-              
          phone expense deductions in dispute are $2,700.                             
               13The parties stipulated that Delaware Corporation made for            
          1995, and deducted in its 1995 return, $18,649 of mortgage loan             
          payments with respect to the Virginia Beach property.  Delaware             
          Corporation’s notice showed that for the taxable year 1995                  
          respondent disallowed $11,676 of mortgage loan interest deduc-              
          tions with respect to that property.  The record does not dis-              
          close the reason for the discrepancies between the total amount             
          of mortgage loan payments that the parties stipulated Delaware              
          Corporation made during 1995, and deducted in Delaware Corpora-             
                                                             (continued...)           





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