Estate of David J. Dickerson, Deceased, Dorothy Dickerson, Executor and Dorothy Dickerson, et al. - Page 37

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                    h.  The Central Valley Towing document is                         
               duplicated several times.  The insurance application is                
               duplicated several times.  The check made out to                       
               Gilbert Insurance is duplicated several times.  The                    
               Swift Dodge document is duplicated several times.                      
               Michoff, Jr., has offered no evidence that the claimed                 
          deductions were ordinary and necessary to a trade or business.              
          The receipts offered do not indicate that they were incurred with           
          regard to the limousine activity of Michoff, Jr., or with regard            
          to any business activity.  Additionally, many of the receipts               
          offered to substantiate the claimed deductions were duplicated              
          and were for tax years not subject to this issue.  Michoff, Jr.,            
          has failed to substantiate most of his claimed deductions, and he           
          has failed to establish that any of the claimed deductions were             
          for expenses ordinary and necessary to a trade or business.                 
          Accordingly, respondent's determination regarding this issue is             
          sustained.                                                                  
          Failure To Timely File Federal Income Tax Returns                           
               Respondent contends that Michoff, Jr., is liable for the               
          addition to tax for failure to timely file for the 1986 and 1987            
          tax years.  Michoff, Jr., contends that he had less than $3,000             
          of income for each of those years and thus was not required to              
          file a return.  It is undisputed that Michoff, Jr., failed to               
          file an income tax return for the 1986 and 1987 tax years.                  
               Section 6651(a) provides an addition to tax for failure to             
          timely file an income tax return by the prescribed due date                 
          unless the taxpayer can establish that such failure was due to              
          reasonable cause and not willful neglect.  Although reasonable              



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