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depreciable basis, and its business percentage use.
The record includes a number of documents related to the
Ford F150 and the GMC Suburban. These documents convincingly
demonstrate that petitioner had an ownership interest in the Ford
F150, but that the GMC Suburban was owned by Clifton Lamb,
petitioner’s older son.
We are unable to credit the testimony of petitioner that
Clifton was merely her nominee. Without the Suburban, Clifton
would have been without a vehicle, and petitioner’s testimony
that he relied on his girlfriend to drive him around is not
persuasive.
Based on the foregoing, we hold for respondent on this
issue.
3. Vehicle Operating Expenses
Petitioner claimed car and truck expenses of $16,029 for the
use of the Ford F150 and the GMC Suburban. Petitioner based the
deduction on actual expenses incurred and not the standard
mileage rate. Respondent allowed a deduction in the amount of
$8,341 for the use of the Ford F150 and disallowed the remainder.
At trial, respondent conceded that petitioner was entitled to an
additional deduction for the Ford F150 for interest expense in
the amount of $656.77.
Petitioner appears to be content with the deduction allowed
and conceded by respondent for the use of the Ford F150. In
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