Elliot S. and Darlene M. Saffran - Page 4

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          expenses deduction.  Respondent disallowed $8,328 of the claimed            
          employee benefit programs expense deduction, and instead allowed            
          $4,996 for self-employed health insurance.  Respondent disallowed           
          the deduction for pension and profit-sharing plans expense in               
          full.  Respondent disallowed the deduction for other expenses of            
          $5,371 and instead allowed a depreciation deduction of $1,301 for           
          the computer and software.  Respondent recharacterized the health           
          insurance deducted as “employee benefit programs of $8,328" as an           
          adjustment to gross income and allowed 60 percent of that amount            
          or $4,996 as a deduction.  Respondent disallowed $5,371 of the              
          claimed “other expenses”.                                                   
               Section 162(a) allows a deduction for ordinary and necessary           
          expenses paid or incurred during the taxable year in carrying on            
          a trade or business.  Taxpayers, however, must maintain                     
          sufficient records to establish the amount of the claimed                   
          deductions.  Sec. 6001; sec. 1.6001-1(a), Income Tax Regs.                  
               Section 274(d)(4) imposes stringent substantiation                     
          requirements for the deduction of certain listed property defined           
          under section 280F(d)(4).  Listed property includes, inter alia,            
          automobiles and computers.  Sec. 280F(d)(4)(A).  To deduct                  
          expenses for such listed property, including depreciation,                  
          taxpayers must substantiate by adequate records the following               
          items:  The amount of each separate expenditure, the listed                 
          property’s business and total usage, the date of the expenditure            






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