Michael L. and Ann Burski - Page 7




                                         -6-                                          
          necessary business purposes and that any amount qualifies as a              
          business expense as specified under the provisions of the                   
          Internal Revenue Code.  Respondent, however, allowed petitioners            
          to deduct the following expenses as unreimbursed employee                   
          expenses on Schedules A, Itemized Deductions:                               
               Expense                             2001        2002                   
               Depreciation                     $518         -0-                      
               Insurance                        527          $827                     
               Legal and professional           104          85                       
               Office expenses                  57           75                       
               Supplies                         324          152                      
               Utilities                        -0-          1,334                    
               Other expenses                   407          785                      

               Respondent did not allow petitioners any deduction for the             
          following expenses:                                                         
               Expense                            2001        2002                    
               Car and truck                    $4,830       $3,362                   
               Depreciation                     -0-          5,913                    
               Insurance                        -0-          44                       
               Repairs and maintenance          1,446        -0-                      
               Travel                           23,532       4,385                    
               Meals and entertainment          3,103        3,810                    
               Utilities                        785          -0-                      

               Petitioners timely filed a petition in this Court seeking              
          redetermination of the deficiencies.                                        
               Petitioners concede that they are not entitled to deduct the           
          $1,446 claimed for repairs and maintenance expenses in 2001.                








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