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conclude that petitioners have not met their burden of
substantiating the deduction for an additional $7,998 in interest
expenses. Rule 142(a).
Petitioners claimed car and truck expenses in the amount of
$56,542, which respondent allowed to the extent of $49,989,
insurance expenses on vehicles in the amount of $18,410, which
respondent allowed to the extent of $16,873, and tax and license
expenses in the amount of $4,605, which respondent allowed to the
extent of $543. At trial, however, petitioners failed to offer
adequate evidence to meet the strict substantiation requirements
of section 274(d)(4) or otherwise show that the requirements of
section 274(d)(4) do not apply to such expenses. Accordingly, we
conclude that petitioners have failed to establish allowable car
and truck expenses, insurance expenses, and tax and license
expenses beyond those allowed by respondent.
Petitioners claimed office expenses in the amount of $706,
which respondent disallowed in full. Mrs. Brown testified that
she ran the office for Mr. Brown's tree stumping business and
that she spent $706 for stamps, envelopes, tape, staples, paper,
pens, and folders. We are satisfied by the record in the instant
case that petitioners incurred $706 in office expenses.
Petitioners claimed repair expenses in the amount of
$56,665, which respondent disallowed in full.4 Mrs. Brown
4 The parties' stipulations categorized petitioners' tire
(continued...)
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