Eli and Karen Yecheskel - Page 4

                                        - 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.                                                         




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