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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.
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