- 15 - expenses beyond what respondent already has allowed. For instance, in support of the disputed car and truck expense for 1987, petitioner introduced into evidence a $300 invoice for the installation of a car phone in a new Mercedes automobile. Petitioner has failed to convince us that that expense did not have substantial, if not exclusive, personal attributes. He has failed to convince us that his 1988 car and truck expense related to a vehicle used in his business. Also, he has failed to provide any detail or supporting documents concerning the category “Office, Rent, & Utilities”. He testified that the category “Dues” included magazine subscriptions. Petitioner has not proven that any of the disallowed expenses were incurred in connection with his business of horse racing and breeding. Accordingly, we sustain so much of respondent’s determination as relates thereto. III. Disputed Additions to Tax A. Failure To File--1987 By her notice of deficiency, respondent determined an addition to tax against petitioner under section 6651(a)(1) for 1987. Section 6651(a)(1) provides that, in the case of a failure to file an income tax return by the due date, there shall be imposed an addition to tax for such failure of 5 percent of the amount of tax, reduced by timely payments and credits under section 6651(b)(1), for each month or portion thereof during which the failure continues, not exceeding 25 percent in thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
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