- 32 - C. Landscaping Petitioners seek to deduct under section 162 as business expenses of Mayor and KareMor charges for landscaping and related maintenance. Portions of the amounts claimed have been allowed or conceded by respondent. In support of these deductions, the record contains principally a number of handwritten invoices from, and copies of checks made payable to, Audelio Rios, also known as Delio Rios. Many of the invoices provide few details as to the work performed, and what notations are included frequently appear to be written in Spanish. At trial, Mr. Deihl and Mr. Hartmann testified that Mr. Rios performed landscaping and maintenance for the corporate property on 24th Street, for petitioners’ residence, and for the residence of Joe II, which was located on Mountainview Drive. Certain of the invoices also contain references to “Biol Dihol” or “3 casas” or “3 houses”, and respondent argues that Mr. Rios provided services at Bill’s residence as well. To the extent that the expenditures were incurred for landscaping and maintenance on the residential premises of petitioners and either of their two sons, any deductions are precluded by section 280A for reasons essentially identical to those just discussed in connection with the improvements to petitioners’ home. The definition of “dwelling unit” for purposes of section 280A includes “other property appurtenant toPage: Previous 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 Next
Last modified: May 25, 2011