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For both years, the car and truck expenses were claimed with
respect to a vehicle placed in service for business purposes on
July 1, 1994. On line 44 of Schedule C, petitioners reported
that the vehicle was used 55,600 miles for business, 2,400 miles
for commuting, and 0 for other, in 1999. For 2000, petitioners
reported that the vehicle was used 24,000 miles for business, 0
miles for commuting, and 2,500 miles for other.
Petitioners claimed and respondent allowed deductions for
the following Schedule E expenses for the Morningside Heights
dwelling. For 1999:
Claimed Allowed
Deductions On Sch. E On Sch. E
Insurance $350 -0-
Taxes 516 -0-
Depreciation 456 -0-
For 2000:
Claimed Allowed
Deductions On Sch. E On Sch. E
Insurance $350 -0-
Taxes 516 -0-
Depreciation 456 -0-
Although disallowed on Schedule E, the petitioners’ deductions
for real estate taxes paid were allowed by respondent as itemized
deductions on Schedule A, Itemized Deductions.
The first issue is whether petitioners are entitled to
certain deductions claimed on Schedule C in excess of amounts
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