- 9 - other than his own testimony that he "feels" that he drove approximately 20,000 miles a year for business purposes. Section 274(d) provides that no deduction shall be allowed with respect to any listed property (as defined in section 280F(d)(4)) unless the taxpayer substantiates by adequate records or sufficient evidence corroborating the taxpayer's own statement the amount of such expense, the time and place of the expense, the business purpose of the expense, and the business relationship of the expense. A passenger automobile is considered listed property. Sec. 280F(d)(4). Because petitioner failed to satisfy the record keeping or other substantiation requirements of section 274(d), petitioners are not entitled to the claimed employee business deductions for automobile expenses for 1989, 1990, and 1991. Issue 3. Statute of Limitations Defense The next issue for consideration is whether respondent is time-barred from amending her answer to increase the amount of the deficiency for 1988 by recharacterizing the advances petitioner received in 1988 as wages. For 1988, petitioners reported a total gross income of $82,034, consisting of wages ($77,388), interest ($3,318), and unemployment compensation ($1,328). In addition, they reported the sale of their home, but excluded the gain therefrom pursuant to section 1034. The reported selling price for the home was $180,000; the excluded gain was $14,050.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011