Mark D. and Sheldon C. Morgan - Page 9

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          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.                                              




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