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was used in his trade or business or other profit-seeking
activity. Accordingly, we sustain respondent on this issue.
Rental expense
On the Schedule C attached to petitioner's 1991 return,
petitioner claimed a deduction in the amount of $3,500 for rental
expense. Respondent has allowed $840.
According to petitioner's testimony, he received bills from
REP for various support services that he used during 1991.
However, petitioner presented no documentation such as receipts,
invoices, canceled checks, or detailed testimony to substantiate
the amounts he spent, or the amounts charged by REP, for support
services. Thus, petitioner has failed to substantiate the amount
disallowed. Accordingly, we sustain respondent on this issue.
To reflect the concessions in this case,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011