Alonzo and Emma J. Bradley - Page 7

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          four properties on the grounds that petitioners (i) failed to               
          establish that the expenses were paid or incurred during the                
          taxable year and/or (ii) failed to establish that the expenses              
          were ordinary and necessary.  Respondent also disallowed the                
          $8,203 in depreciation claimed on the grounds that petitioners              
          (i) failed to establish their cost or other basis in the                    
          properties and/or (ii) failed to establish that the properties              
          were depreciable.                                                           
               Petitioners' return was due on April 15, 1993.  The return             
          was executed by petitioners on April 26, 1993, and filed on or              
          about that date.                                                            


                                       OPINION                                        
          Employee Vehicle Expenses                                                   
               Respondent argues that petitioners failed to substantiate              
          their deductions for vehicle expenses as required by section 274            
          because they failed to establish the business use of their                  
          personal automobiles, as well as the location or destination of             
          travel, and the business purpose.4                                          




               4Respondent also argues in the alternative that Mr.                    
          Bradley's vehicle expenses were not "ordinary and necessary"                
          because they were reimbursable by his employer or because the               
          shuttle and taxi services were available.  Because we find that             
          petitioners fail to satisfy sec. 274 with respect to Mr.                    
          Bradley's vehicle expenses, we do not address respondent's other            
          arguments.                                                                  




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