- 3 -
1972). Petitioners did not satisfy their burden of
substantiating their expenses. In addition, they failed to
establish that Silverton would not have reimbursed Mr. Appling
for the expenses at issue. Accordingly, petitioners are not
entitled to deduct the unreimbursed employee expenses at issue
for 1992, 1993, and 1994.
On their 1992 Federal income tax return, petitioners also
claimed a $10,809 Schedule C loss ($3,700 of gross receipts minus
$14,509 of expenses) relating to a business which marketed a car
wash product called "Dri Wash 'N Guard". Respondent determined
that petitioners were not entitled to deduct any losses
attributable to this activity. Respondent concedes, however,
that petitioners purchased $4,246 of the car wash product. Based
on concessions, testimony, reconstructed records, and executed
checks, we conclude that petitioners had expenses totaling
$4,831.23. Accordingly, petitioners are entitled to a $1,131.23
Schedule C loss for 1992.
On their 1993 and 1994 Federal income tax returns,
petitioners also claimed Schedule C losses of $18,008 and
$14,981, respectively, for a mining business. Petitioners have
failed, however, to prove that they sustained such losses.
Accordingly, petitioners are not entitled to Schedule C losses
for 1993 and 1994.
Page: Previous 1 2 3 4 Next
Last modified: May 25, 2011