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petitioners for seminars totaled less than $500 and do not meet
that threshold. The travel expenses claimed by petitioners were
not substantiated as required by section 274(d). No
contemporaneous documents or other reliable evidence corroborated
the alleged business purpose of the travel.
Petitioners contend that the repairs and maintenance expense
related to an office in their home. The only evidence on this
issue is Mr. Nordbrock’s uncorroborated and conclusory testimony.
The documentation that was presented consisted of checks without
invoices and credit card charges, and the documentation showed no
allocation between an alleged office in the home and the personal
residential quarters of petitioners. Petitioners failed to
present reliable or persuasive evidence that would satisfy the
conditions of section 280A(c).
After examination of the documents submitted by petitioners
and petitioners’ testimony, we conclude that any additional
expenses beyond those conceded by respondent are not adequately
substantiated.
There is no excuse for petitioners’ failure to present
substantiating materials during the administrative stages and for
more than a year while these cases were pending. They
disregarded the Court’s order that they produce documents for
1996 and 1997. They are familiar with the consequences of
failing to produce documents when required by law or Court order
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Last modified: May 25, 2011