Mary K. Fisher and Charles F. Patterson, et al. - Page 22

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          The list, which was not compiled contemporaneously, consists of             
          petitioner's estimates.  The record also contains several of                
          petitioner's monthly credit card statements dated 1987,                     
          purportedly indicating that petitioners incurred startup expenses           
          attributable to the purchase of tack and other supplies in the              
          amount of $6,864.                                                           
               Petitioners' list is inadequate for the purposes of                    
          substantiating the expenses in question.  Petitioner did not                
          contemporaneously compile the list, and we do not accept                    
          petitioner's self-serving estimates of the expenditures in issue.           
          Cf. Farguson v. Commissioner, T.C. Memo. 1983-615 (rejecting                
          taxpayer's poorly detailed and noncontemporaneous ledger as                 
          inadequate for substantiating purported expenses).  Furthermore,            
          many of the expenditures in question relate to the purchase of              
          bridles, saddles, and other equipment which had a useful life               
          beyond the year in which they were purchased.  These expenditures           
          are capital expenditures, and cannot be considered as startup               
          expenditures.  S. Rept. 96-1036, supra at 12; sec. 1.263(a)-2(a),           
          Income Tax Regs.; cf. Rodgers Dairy Co. v. Commissioner, 14 T.C.            
          66, 71 (1950) (allowing taxpayer's claim for depreciation with              
          respect to bridles and saddles).  Although the credit card                  
          receipts indicate that petitioners may have incurred expenses               
          related to their horse-breeding and racing activities prior to              
          1988, we cannot discern from the record those items constituting            






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