- 7 -
did not testify or provide any evidence about his gas expenses or
tolls. Petitioner did not have a log, records, or other
corroboration showing the mileage, dates, locations, or business
purpose of any of the vehicle trips as required under section
274(d)(4). We conclude that he may not deduct more than
respondent has allowed.
3. American Express Charges
Petitioner contends that he used his American Express credit
card to pay $11,278 more than respondent allowed for Elan’s
expenses. He testified that the payments were for business
meals, but he conceded that he could not substantiate that any of
these meals had a strict business purpose. Petitioner has not
met the substantiation requirements of section 274(d)(1).
4. Depreciation
Petitioner contends that respondent should have allowed Elan
to claim an additional $3,090 for depreciation. We disagree.
Elan is not a party here; even if it were, petitioner has not
offered any evidence to show that Elan is entitled to additional
depreciation.
5. Conclusion
We conclude that petitioner paid $26,134 of Elan’s business
expenses from the $146,193 which he received for Elan but did not
deposit in Elan’s bank account.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011