Octavio and Felicitas Olvera - Page 8

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          274(d).  Listed property includes automobiles and cellular                  
          telephones.  Sec. 280F(d)(4).  Section 274(d) requires                      
          substantiation of these expenses either "by adequate records or             
          by sufficient evidence corroborating the taxpayer's own                     
          statement".                                                                 
               Petitioner testified that his business mileage was based on            
          an estimate.  He also testified that his 1993 telephone expense             
          represented amounts paid to a friend from whom he borrowed a                
          cellular phone.  Petitioners presented no records or                        
          corroborating evidence with respect to these expenses, and they             
          have failed to substantiate any amount in excess of that allowed            
          by respondent.  Respondent is sustained on this issue.                      
               To reflect the foregoing,                                              

                                                  Decision will be entered            
                                             under Rule 155.                          




















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