Suzanne Z. Ataky - Page 2




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               The issues for decision are whether petitioner is entitled             
          to ordinary deductions for (1) a $3,050 casualty loss, (2) a                
          $2,060 business bad debt, (3) a $2,940 business travel expense,             
          (4) a $3,850 business contract labor expense, and (5) $2,186 more           
          in depreciation than respondent allowed.1                                   

                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
               At the time the petition was filed, petitioner resided in              
          New York, New York.                                                         
               Petitioner works full time as a respiratory therapist.                 
               In 2002, petitioner’s car was stolen and recovered.  As a              
          result of the theft, petitioner’s car was damaged.  The                     
          individual who stole petitioner’s car was not apprehended, and              
          petitioner’s car insurance policy did not cover the theft damage            
          to petitioner’s car.                                                        
               In 2003, petitioner was involved in a minor 2-car accident,            
          and again petitioner’s car was damaged.  Petitioner did not                 
          request from the driver of the other car payment for the damage             
          to petitioner’s car, and petitioner did not repair the damage to            
          her car.  Petitioner did not obtain an estimate of the fair                 
          market value of her car before and after the accident.                      




               1 The $2,186 in disputed depreciation also includes a sec.             
          179 expense deduction.                                                      





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