Elliot S. and Darlene M. Saffran - Page 7

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          he paid any such expense.  Therefore, we sustain respondent on              
          this issue.                                                                 
               The “other expenses” deduction of $5,371 included the cost             
          of a computer and software.  Respondent disallowed the $5,371.              
          However, respondent allowed a depreciation deduction of $1,301              
          for the computer and software.  Petitioner provided no evidence             
          that he was entitled to a greater deduction than allowed by                 
          respondent, nor did he prove that he properly elected to expense            
          the computer and software under section 179.  Again, we sustain             
          respondent.                                                                 
               Contentions we have not addressed are irrelevant, moot, or             
          without merit.                                                              
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   


                                                  Decision will be entered            
                                             for respondent.                          

















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