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Supplies
Respondent disallowed Mr. Kerrigan's entire Schedule C
deduction for supplies in the amount of $6,143.23. On brief,
respondent concedes that petitioners have substantiated a
deduction of $98.25. At trial, petitioners presented credit card
receipts totaling $226.64. Most of these receipts were for
purchases at the Drug Fair in Potomac, Maryland. Descriptions on
the receipts of the various purchases are either nonexistent or
illegible. Because petitioners have failed to substantiate a
business purpose for this deduction, we sustain respondent's
disallowance of these expenses except for the $98.25 which
respondent concedes.
Insurance Expenses
Respondent disallowed Schedule C deductions for insurance
expenses by Mrs. Kerrigan and Mr. Kerrigan in the respective
amounts of $571 and $146.96. Petitioners presented insufficient
evidence at trial to convince us that they are entitled to these
deductions. Petitioners produced an insurance bill from the Erie
Insurance Co. in the amount of $238. We are uncertain, however,
of the date on which this bill was either issued or paid.5 We
therefore sustain respondent's determination.
5We note the apparent similarity between this bill and the
car and truck expense deduction claimed by Mrs. Kerrigan for a
$238 payment to the Erie Insurance Co. on Jan. 7, 1985.
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