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testified that Mr. Brown purchased truck parts, tractor parts,
track, welding materials, acetylene, oxygen, welding rods,
wrenches, rollers, engines, hydraulic systems, and a set of
rails. Mr. Brown testified that a set of rails (treads for the
tractor) costs approximately $5,000-7,000 but failed to provide
the cost of any of the other parts that he purchased. Mr. Brown
testified that he did some repair work on his own in the
Fruitdale shop. Additionally, he testified that he took more
difficult repair jobs to a garage in Richland. On the basis of
the record in the instant case, we approximate petitioners'
repair expense to be $40,000 during 1991.
Petitioners claimed travel expenses in the amount of $3,417,
which respondent disallowed in full. Mrs. Brown testified that
Mr. Brown incurred travel expenses when he performed work out of
town and when he traveled to Florida to purchase parts.
Petitioners, however, did not produce adequate records or
sufficient evidence substantiating their travel expenses as
required by section 274(d). Accordingly, we sustain respondent's
disallowance in full of petitioners' claimed travel expenses.
4(...continued)
expense as a car and truck expense. At trial, however,
petitioners argued that their repair expenses consisted of
$41,058 for parts and $15,067 for tires. As we have addressed
petitioners' tire expense in the car and truck category, the
amount in issue in the repair expense category is limited to
$41,058 for parts.
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