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Petitioner claims that his Schedule C trade or business is
“being an employee for livelihood or for profit.” As
petitioner’s trade or business is being an employee, these
expenses are subject to the 2-percent limitation of section 67
and further limitations under section 68.
D. Listed Expenses
After concluding that petitioner is entitled to deduct
expenses associated with his employment with Craft-Barnett
subject to the limitations contained in sections 67 and 68, we
must examine each expense listed by petitioner to determine any
further limitation on deductibility.
1. Car and Truck Expenses
Petitioner is entitled to deduct the expenses listed as car
and truck expenses because automobile expenses are specifically
listed in the corporate resolution. Petitioner used his truck to
travel from his office to job sites, the bank, and title
companies. Therefore, petitioner is entitled to deduct the
$2,245.40 of car and truck expenses.3
2. Depreciation Expense
Petitioner claimed $8,846.98 in depreciation expenses on his
2001 return of which $6,760.35 is related to his truck and
$2,086.63 is related to office equipment.
3 Respondent states that he does not raise the issue of
compliance with the substantiation requirements of sec. 274(d),
and therefore sec. 274 is not an issue.
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