- 8 -
checking account. In fact, other than an escrow account,
petitioner did not maintain any other checking account.
Assuming that all the checks in fact relate to storage
expenses, we have only petitioner’s uncorroborated testimony that
the expenses were incurred in carrying on a trade or business as
opposed to personal expenses incurred in anticipation of, and
during, his change of personal residence. Petitioner testified
that he was requested to provide respondent with information that
would serve to substantiate his claimed office expenses.
However, petitioner also testified that he did not attempt to
contact Black Horse Self Storage to secure any documentation,
even though he signed a lease agreement with the storage facility
company. Based on this record, petitioner has not met his burden
and established his entitlement to these claimed deductions.
(II). Oriental Rugs and Art
The third office expense at issue relates to items allegedly
purchased by petitioner in 1994. Petitioner testified that he
purchased three used oriental rugs for $6,050 and art for $1,400
and then placed these items in his Pennsauken, New Jersey and
Philadelphia, Pennsylvania offices. Petitioner produced copies
of two checks, one payable to Togar, Inc., for $6,050 and one
payable to Lucien Crup for $1,400. Neither check contained a
notation regarding its intended purpose.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011