- 9 - Randall did not keep a regular set of books reflecting the income and expenses associated with his financial planning business. To substantiate the office expenses and meals and entertainment here in issue, petitioners refer us to (1) various entries in a diary, Randall’s “daily planner”, (2) his NationsBank VISA card summary statement for 1994, and (3) various receipts relating to meals and entertainment expenses and office expenses. We must decide whether and to what extent that evidence is adequate to substantiate the business expense deductions that remain in issue. With respect to the items of office expense set out on petitioners’ substantiation schedule, with four exceptions, petitioners’ evidence fails to satisfy one or more of the elements necessary to establish deductibility as ordinary and necessary business expenses under section 162. For example, a number of items are listed in Randall’s daily planner, indicating a business purpose, but do not appear in the NationsBank VISA card summary or relate to one of the receipts in evidence. In other words, there is no proof of payment. For other items, there is proof of payment, but the items are not listed in the daily planner resulting in a failure to establish a relationship to Randall’s business.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