- 6 - Amoco. It is unclear what charges these checks were intended to cover. Finally, petitioners introduced adding machine "tape totals" that were attached to the charge slips they introduced. These "tape totals" contain two line items for which no charge slips can be found. One line item is for $2,113.57. The only evidence of its payment is a piece of the "tape total" stapled to a series of charges from Carter's Amoco for purchases in April 1987. On the tape piece is the notation "Paid in full". The other line item is for $1,192.09. The only evidence that this amount was paid is a handwritten notation appearing on a January 2, 1987, charge slip from Carter's Amoco stating "Pd in full 1192.09 1-2- 87". The handwriting appears to be different from the handwriting of the person that prepared the charge. Even including these two line items from the "tape totals" and the carbon copies of the checks from Dollar Bank, petitioners have presented evidence that they paid only $9,759.71 of car and truck expenses for 1987. This figure falls short of the amount already allowed by respondent. Petitioners have also failed to prove that these expenses were ordinary and necessary business expenses within the meaning of section 162(a). Neither the charge slips nor the copies of the checks from Dollar Bank indicate the requisite business purposes for petitioners' expenditures. See sec. 1.162-1(a), Income Tax Regs. We therefore sustain respondent's determination.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011