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Petitioners did not offer evidence to demonstrate any
allocation of Dr. Rinker’s Internet fees between personal and
business uses. Petitioners have therefore not provided the Court
with an adequate basis upon which to make a Cohan estimation, and
we allow petitioners no deduction for the claimed expenditures.
See Cohan v. Commissioner, supra at 544.
13. Office Cleaning
On their Schedule C for Dr. Rinker’s medical practice for
1999, petitioners claimed a deduction of $598 for cleaning
services. Dr. Rinker testified that she engaged a cleaning
service company to clean both her office and her home during
1999, and that her total payments to the cleaning service
exceeded $5,000. Dr. Rinker testified that she based the $598
figure on the number of times the service visited her office and
the amount of the weekly payments she made to the company in
1999.
Dr. Rinker’s expenditures for office cleaning were ordinary
and necessary expenditures directly connected with her medical
practice. See sec. 1.162-1, Income Tax Regs. We therefore allow
a deduction of $598.
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