Carolyn Lamb - Page 13

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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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