- 4 - Insurance $ 600 Rent or lease of vehicles 15,333 Taxes and licenses 120 Total $16,053 Respondent disallowed the expenses on the ground that the expenses related to travel and transportation, and petitioners had failed to establish that the expenses were (a) incurred during the taxable year, and (b) were ordinary and necessary business expenses. The determinations of the Commissioner in a notice of deficiency are presumed correct, and the taxpayer bears the burden of proving that the determinations are incorrect. Rule 142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933). The $15,333 item that petitioner claimed as an expense for the rent or lease of vehicles represented the cost of a Mercury Sable automobile petitioner purchased for cash on July 3, 1992. That automobile was used exclusively in petitioner's Schedule C activity by himself and his clients.4 Petitioners presented no documentary information to substantiate the $600 claimed for insurance and the $120 claimed for taxes and licenses. 4 Petitioner paid for the automobile by issuance of a check in the amount of $15,313 payable to the dealer. No explanation was advanced to account for the $20 difference between the amount of the check, $15,313, and the amount claimed as an expense on Schedule C, $15,333.Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011