Rahim A. and Lisa R. Munshi - Page 7

                                                - 7 -                                                 

            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.                                 

Page:  Previous  1  2  3  4  5  6  7  

Last modified: May 25, 2011