Tibor Guenther Horwath and Christel Horwath - Page 11

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          replacement cost of that simulator.  In Schedule C of petition-             
          ers’ 1998 return (Mr. Horwath’s 1998 Schedule C), petitioners               
          claimed a depreciation deduction of $57,100 with respect to the             
          computer simulator and a deduction of $16,812 for the travel                
          expenses that Mr. Horwath paid in 1998.                                     
          Notice of Deficiency                                                        
               On August 1, 2002, respondent issued to petitioners a notice           
          of deficiency (notice) with respect to their taxable years 1997             
          and 1998.  In that notice, respondent determined, inter alia,               
          that petitioners are not entitled to the depreciation deductions            
          of $75,250 and $57,100 claimed with respect to the computer                 
          simulator in petitioners’ 1997 return and petitioners’ 1998                 
          return, respectively.  Respondent also determined in the notice,            
          inter alia, that petitioners are not entitled to $14,686 of the             
          $16,812  deduction that petitioners claimed for the travel                  
          expenses that Mr. Horwath paid in 1998.2  Respondent further                
          determined in the notice that petitioners are liable for each of            
          the taxable years at issue for the accuracy-related penalty under           


               2Petitioners claimed a deduction of $16,812 for travel                 
          expenses in petitioners’ 1998 return.  Respondent allowed $2,126            
          of that amount.  The record does not disclose why respondent                
          allowed $2,126 of the claimed $16,812 travel expenses.  The                 
          parties stipulated that the entire amount of travel expenses                
          (i.e., $16,812) was paid by Mr. Horwath in connection with                  
          providing to Primex on TGC’s behalf the consulting services                 
          required by the Primex contract.  (We shall refer to the $14,686            
          in travel expense that respondent disallowed in the notice as Mr.           
          Horwath’s 1998 travel expenses.)                                            





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