Dudley Joseph and Myrna Dupuy Callahan - Page 18

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          $1,166 for insurance on investments, and $20,370 for repairs and            
          depreciation.  Written at the top of Schedule A was "ANDREW", in            
          reference to Hurricane Andrew.  Respondent disallowed                       
          petitioners' claimed miscellaneous deductions for 1991 for lack             
          of substantiation.                                                          
               As noted, taxpayers are generally required to substantiate             
          claimed deductions and credits by maintaining the records needed            
          to establish the amount of such items.  Sec. 6001; sec. 1.6001-             
          1(a), Income Tax Regs.  Petitioners did not elaborate upon which            
          of the reported Schedule A expense deductions related to                    
          Hurricane Andrew, although petitioner did testify that "labor"              
          expenses reported on line 21 of Schedule C for that year were for           
          repairs caused by Hurricane Andrew.  Petitioners submitted                  
          photocopies of hundreds of checks, whose payees included Southern           
          Bell, Reader's Digest, American Family Publishers, J.C. Penney              
          Insurance, Allstate Insurance, Shell, Exxon, Texaco, and "cash,"            
          among others.  Most of the checks do not indicate what was                  
          purchased or the purpose of the expenditure.  When asked to                 
          clarify the stock and insurance expenses, petitioner testified              
          only that the stock was purchased to create a "perpetual fund for           
          the maintenance of" their parents' graves.  We find both the                
          photocopies of the checks and petitioner's testimony insufficient           
          to substantiate the Schedule A miscellaneous deductions claimed             
          for 1991.  Respondent is sustained on this issue.                           






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