Anke Lunsmann-Nolting - Page 14

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          evidence presented.  Rule 142(a); Welch v. Helvering, supra at              
          115.                                                                        
               The evidence does not support a finding that deductions                
          relating to the cottages are ordinary and necessary.  While it              
          may be helpful to petitioner’s job as a fundraiser to have                  
          lodging available for donors and scientists during events in                
          Maine, it is not common or appropriate for a fundraiser or an               
          employee of a medical school to purchase and maintain real                  
          property for that purpose.                                                  
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   


                                                  Decision will be entered            
                                             under Rule 155.                          






















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