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1995. Respondent disallowed the $112,413 and $131,014 deductions
for 1993 and 1994, respectively, on account of a lack of
substantiation as well as petitioners’ failure to establish that
the expenses were ordinary and necessary.
At trial, petitioner failed to present any evidence,
documentary or otherwise, to substantiate the claimed supply
expenses. Consequently, we sustain respondent’s position on this
issue.
3. Returns and Allowances for 1995
Petitioner claimed Schedule C returns and allowances for the
tax year 1995 in the amount of $454,387. Respondent disallowed the
deduction and adjustment on account of petitioner’s lack of
substantiation.
Again, at trial, when asked if he had anything to substantiate
his returns and allowances for 1995, petitioner stated “I just
don’t have a thing.” Petitioner presented no evidence to
substantiate entitlement to the amounts claimed. Again, we must
sustain respondent’s determination on this issue.
4. Conclusion
Petitioners failed to substantiate any of the amounts claimed
on the Schedules C that were disallowed in the notice of
deficiency. Instead of providing documentary evidence to attempt
to substantiate the amounts claimed, petitioner chose to rely
solely on his testimony. Petitioner did not call as witnesses the
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