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similar to the facts of Malek v. Commissioner, T.C. Memo. 1985-
428, wherein this Court held such expenses were not deductible.
Petitioners did not maintain books and records as required by
section 6001 to substantiate other deductions and, in particular,
expenses subject to section 274(d). Petitioners claimed
depreciation on an asset although petitioners had scant evidence
as to its basis. Finally, one of the expenses claimed as a
business expense was found to be for the personal enjoyment of
Mrs. Zeidler. On this record, the Court sustains respondent on
the penalty under section 6662(a).
Decisions will be entered
under Rule 155.
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