- 7 - four properties on the grounds that petitioners (i) failed to establish that the expenses were paid or incurred during the taxable year and/or (ii) failed to establish that the expenses were ordinary and necessary. Respondent also disallowed the $8,203 in depreciation claimed on the grounds that petitioners (i) failed to establish their cost or other basis in the properties and/or (ii) failed to establish that the properties were depreciable. Petitioners' return was due on April 15, 1993. The return was executed by petitioners on April 26, 1993, and filed on or about that date. OPINION Employee Vehicle Expenses Respondent argues that petitioners failed to substantiate their deductions for vehicle expenses as required by section 274 because they failed to establish the business use of their personal automobiles, as well as the location or destination of travel, and the business purpose.4 4Respondent also argues in the alternative that Mr. Bradley's vehicle expenses were not "ordinary and necessary" because they were reimbursable by his employer or because the shuttle and taxi services were available. Because we find that petitioners fail to satisfy sec. 274 with respect to Mr. Bradley's vehicle expenses, we do not address respondent's other arguments.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011