W. Bradford Davis and Tedde M. Rinker - Page 24

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          associations of approximately $1,185.  On their 1999 return,                
          petitioners deducted $700 for “Taxes and licenses” on the                   
          Schedule C for Dr. Rinker’s medical practice.  Respondent allowed           
          this amount in full.  It appears likely that petitioners included           
          the cost of Dr. Rinker’s medical license fee in the deduction for           
          “Taxes and licenses.”  Petitioners have therefore not established           
          that they paid any amount relating to Dr. Rinker’s medical                  
          license in excess of the amount respondent allowed.  See Rule               
          142(a); Welch v. Helvering, 290 U.S. 111 (1933).                            
               Dues to professional organizations are generally deductible            
          under section 162.  Sec. 1.162-6, Income Tax Regs.  Pursuant to             
          Cohan v. Commissioner, supra at 544, we allow a deduction of $550           
          for the remaining expenditures for Dr. Rinker’s professional                
          dues.                                                                       
          12.  Internet Services                                                      
               Dr. Rinker testified that she paid approximately $24 per               
          month for Internet access in 1999.  She testified that she                  
          maintained the account so that she could communicate with                   
          patients via e-mail, but that she also used the account for                 
          personal purposes.  Dr. Rinker also testified that she paid                 
          another charge in connection with her business use of the                   
          Internet, but she could not recall whether she incurred the                 
          charge in 1999 or 2000.                                                     







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