Aziz A. Tokh and Susan K. Tokh - Page 7




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          Petitioner has 24-hour access to the office at NIRC.  NIRC does             
          not require petitioner to maintain an office in the home.                   
          Petitioners did not keep receipts or records for any of their               
          expenses associated with the office in the home, and petitioners            
          used an inflated basis in calculating depreciation expenses.                
          Petitioners claimed deductions for expenses relating to                     
          maintaining the office in the home in 1996 and 1997.                        
               On their 1991, 1994, and 1995 Federal income tax returns,              
          petitioners claimed deductions for estimated employment expenses,           
          investment expenses, charitable contributions, and office in the            
          home expenses that are similar to those claimed during the years            
          in issue.  Petitioners prepared all of the tax returns themselves           
          without the assistance of a paid tax return preparer.  Respondent           
          examined petitioners’ 1991 income tax return and issued a notice            
          of deficiency.  Petitioners filed a timely petition with the                
          Court, and, on October 20, 1994, a stipulated decision was                  
          entered.                                                                    
                                       OPINION                                        
               Respondent argues that petitioners are not entitled to the             
          deductions claimed on their returns because petitioners did not             
          provide any substantiation for the amounts reported.  Petitioners           
          assert that they are entitled to the claimed deductions; however,           
          for the most part, they offered no books or records to prove that           
          they expended the amounts in question.  Only petitioner Aziz A.             





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