- 15 - at issue. However, the summary is titled “supplies”, and there are no disputed deductions on the supplies issue. Exhibit 102 is most deficient, however, with respect to the copies of the receipts included therein. There is no indication of the relationship between the additional expenses and the corporations' business. In order to be deductible, a business expense must be an ordinary and necessary expense of doing business. Sec. 162(a). The receipts do not show the ordinary and necessary business purposes of the expenses, but rather reflect mostly personal items, including groceries and minor office supply items. Even with the supply items listed, there is no way to determine whether these receipts correspond to the additional deductions claimed. Exhibit 102 does not carry petitioners’ burden of substantiating the office expense deductions. Therefore, we uphold respondent’s determination on the office expenses. Petitioners claim additional travel and entertainment expenses for GAPS of $11,119 and for JJM of $3,565. Petitioners’ claim that exhibit 104 supports these deductions. Respondent objects to the exhibit on the grounds of relevancy, lack of completeness, hearsay, and lack of trustworthiness. As with exhibit 102, we find it unnecessary to rule on respondent’s objection, because the evidence on the claimed travel and entertainment deductions is similarly deficient. EvenPage: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
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