Mila Alemasov and Victor Popov - Page 14




                                       - 14 -                                         
          Supplies                                                                    
               Petitioners claimed a $143 deduction for supplies.  To                 
          substantiate this item, petitioners submitted two Visa credit               
          card statements.  The statements indicate petitioners made                  
          purchases at Aaron Brothers, Office Max, and The Container Store            
          in May and November of 2002; the spreadsheets petitioner prepared           
          indicate that these expenses were incurred for frames, notebooks,           
          pens, and “items”.  The relationship of these expenses to                   
          petitioner’s real estate activity was not established.                      
          Petitioners also claim that they paid cash for some supplies, but           
          they did not present any receipts or canceled checks to support             
          these expenses.                                                             
               On the basis of the submitted Visa credit card statements,             
          it is clear that petitioners made purchases at stores that sell             
          office supplies.  There is no evidence, however, other than                 
          petitioner’s self-serving testimony, which we do not find                   
          probative, that these expenses were related to or incurred in               
          connection with petitioner’s real estate activity.  Without                 
          further substantiating evidence, the Court sustains respondent’s            
          determination disallowing such expenses.                                    




               8(...continued)                                                        
          evidence to satisfy the heightened substantiation requirements              
          associated with listed property.                                            






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