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question. At trial, counsel for respondent advised the Court
that petitioners had established their entitlement to deductions
for all the disallowed expenses, except for the following
expenses for the 1990 tax year:9
$930 -- Supplies
162 -- Meals
299 -- Other expenses
909 -- Travel
The Court sustains respondent on each of these items.
Petitioners did not sustain their burden of establishing their
entitlement to a deduction for these expenses. The meals and
travel expenses were additionally subject to the substantiation
requirements of section 274(d), discussed earlier in this
opinion, and petitioners' records as to the meals did not comport
with the record keeping requirements of section 274(d). The $909
travel expense item, however, was disallowed by respondent for a
different reason: the expense related to that portion of Mrs.
Zeidler's travel with Mr. Zeidler on two trips during 1990. One
trip was to North Carolina, and the other trip was to Birmingham,
Alabama. Respondent allowed a deduction for that portion of the
trips allocable to Mr. Zeidler but denied the portion allocable
to Mrs. Zeidler on the ground that the trips, as to her, were not
9
Depreciation of the computer for the 3 years was also one of
the Schedule C expenses disallowed that respondent did not
concede but that issue has been considered by the Court above.
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