Kathleen J. Kelly - Page 7

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            substantiate the amount of each separate expenditure, the amount                          
            of business and total use of the property, the date of the                                
            expenditure or use, and the business purpose for the expenditure                          
            or use.  Sec. 1.274-5T(b)(6), Temporary Income Tax Regs., 50 Fed.                         
            Reg. 46016 (Nov. 6, 1985).                                                                
                  Based on the mileage reported on petitioner's reimbursement                         
            expense reports, on brief respondent concedes that petitioner is                          
            entitled to a deduction for automobile expenses in the amount of                          
            $827.94 using the standard mileage rate.  Respondent contends                             
            that petitioner has failed to substantiate automobile expense in                          
            excess of this amount.  We agree.                                                         
                  It is clear that petitioner paid some automobile insurance                          
            premiums during 1989.  She provided evidence of insurance expense                         
            in the amount of $1,740.61.  Petitioner has not established any                           
            amount paid for the lease of her car.  Petitioner testified that                          
            she claimed 95 percent of her automobile expense as attributable                          
            to business usage of her car.  However, petitioner maintained no                          
            records which would indicate that the business usage of her car                           
            was 95 percent.  Petitioner has not met the requirements of                               
            substantiation under section 274(d).  Accordingly, she is not                             
            entitled to a deduction for automobile expense in excess of the                           
            amount conceded by respondent.                                                            
                  Petitioner contends that she is entitled to a deduction in                          
            the amount of $1,155 for expense incurred with respect to the use                         
            of a computer in her work for Pitney Bowes.  Petitioner testified                         




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