Tobias G. Ogu - Page 6

                                        - 5 -                                         
          Similarly, petitioner did not attach to either of his returns an            
          election to expense property under section 179.5                            
               C.  Petitioner’s “Trade Missions” to Nigeria                           
               On his Schedule C for 1999, petitioner claimed a deduction             
          for “trade mission” in the amount of $11,900.  In this regard,              
          petitioner claims to have gone to Nigeria on a “trade mission”              
          from December 22, 1999, to January 7, 2000, and to have incurred            
          the following “general expenses”:                                           
               Item                                    Amount                         
               Air ticket                              $1,620                         
               Excess luggage                             875                         
               Sealing tape                                 5                         
               Yellow Cab taxi                             65                         
               ABC Transport to Owerri                    150                         
          Domino Paramount Hotel--3 days             225                              
               Taxi to tourist guest house                 45                         
               Tourist guest house–-7 days                665                         
               Hotel conference hall                      570                         
               Banners and signs                          455                         
               Publications and Supplies                1,650                         
               Car rental with chauffeur--8 days          540                         
               Gas/petrol                                 490                         
               Radio advertisement                        500                         
               Lunch for the guests                     1,950                         
               Domino Paramount Hotel--4 days             300                         
               Messengers--hired 5 people                 750                         
               Meal and entertainment                   1,045                         
               Total Expenses                          11,900                         
               The record does not include an itinerary, passenger receipt,           
          boarding passes, credit card receipt, or other documentary                  
          evidence demonstrating that an airline ticket was purchased or,             


               5  A taxpayer wishing to expense property would typically              
          make the election using Part I, Election To Expense Certain                 
          Tangible Property (Section 179), of Form 4562, Depreciation and             
          Amortization (Including Information on Listed Property).                    





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