Ragnhild A. Westby - Page 62

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                         o.  Taxes                                                    
               For the years at issue, petitioner claimed deductions for              
          taxes as follows:                                                           
                         Year                Amount                                   
                         1987                $1,235                                   
                         1988                4,908                                    
                         1989                5,051                                    
                         1990                10,601                                   
               Mr. Aunan’s workpapers, which describe the tax expense                 
          category as “P/R Taxes”, reveal that the following entries                  
          comprised the deducted amounts:                                             
               (a) For 1987, amounts of $491 and $744, for a total amount             
          deducted of $1,235;                                                         
               (b) for 1988, amounts of $382 and $4,526, for a total amount           
          deducted of $4,908;                                                         
               (c) for 1989, a single amount of $2,799 is listed, but the             
          final expense figure shown on Mr. Aunan’s workpapers is $5,051,             
          the total amount deducted on petitioner’s return;                           
               (d) for 1990, a total amount of $10,601.                               
               Our review of the record reveals the following:                        
               (a) For 1987, petitioner documented two payments to the IRS,           
          in September and December 1987, and one payment to the Commission           
          of Revenue, in September 1987, totaling $490.98 (Ex. 38-R, lines            
          803-805).  Respondent concedes the deductibility of these                   
          payments.                                                                   







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