- 33 - 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...)Page: Previous 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 Next
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