- 16 - At trial and on brief, petitioners provide confusing information and ambiguous arguments concerning these two transactions with Christa Oil. During the trial, in response to a question from the Court as to whether petitioners had attempted to obtain the original records of Christa Oil, or its successor, regarding these transactions, the following dialogue occurred between the Court and petitioners' counsel: THE COURT: Mr. Lumerman, do you know the status of Christa Oil and the records? Have you made any attempt to get the records of Christa Oil with regard to the purchase by it of the stock from Mrs. Leavell? MR. LUMERMAN: No, Your Honor, frankly, we haven't. We sustain respondent's determination on this issue in its entirety. Expenses of Various Businesses L & L Supply As indicated, in 1984, Eva started an oil equipment sales business under the name of L & L Supply. On Schedules C attached to petitioners' joint Federal income tax returns for 1985, 1986, and 1987, Eva claimed operating and/or trucking expenses of $106,801, $53,941, and $124,454, respectively, relating to this business. On audit, respondent disallowed for lack of substantiation these claimed expenses of L & L Supply.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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