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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.
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