- 23 - and maintenance bills, and a letter from his automobile insurance provider noting the annual premium. McDonald testified that, during 1989, he drove his automobile 8,000 miles, 90 percent of which represented business miles. Under section 274(d), taxpayers are required to meet certain substantiation requirements in order to be entitled to a deduction for certain business expenses. Section 274(d)(4) (which is effective for taxable years beginning on or after January 1, 1986) requires substantiation for a taxpayer to be entitled to deduct travel expenses. McDonald’s substantiated expenditures connected with his automobile for the 1989 year exceed the total of the $250 monthly payments received from Gold. McDonald offered no records or other evidence, however, of the business use of his automobile other than his testimony, which was expressed in terms of a rough estimate without any meaningful detail or contemporaneous support. McDonald has not met the section 274(d) requirements necessary to show entitlement to transportation deductions, and, accordingly, respondent’s income determination regarding the monthly payments from Gold is sustained. Rule 142(a). Maynard and McDonald both contend that the remainder of payments from Gold to petitioners is attributable to Maynard, even though $6,024 of the checks was written to McDonald from Gold’s Bank of Lodi account. Petitioners, here again, bear the burden of showing error regarding respondent’s determination that $6,024 is income to McDonald and $20,421 is income to Maynard.Page: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Next
Last modified: May 25, 2011