- 10 - unless the taxpayer substantiates by adequate records or by sufficient evidence corroborating the taxpayer's own statement (A) the amount of such expense or other item, (B) the time and place of the travel * * *, (C) the business purpose of the expense or other item, and (D) the business relationship to the taxpayer of persons entertained, using the facility or property, or receiving the gift. * * * In 1992, petitioners did not claim a deduction for car and truck expenses on their Schedule C. Respondent has agreed that petitioners were entitled to deduct $1,680 for car and truck expenses in that year. In 1993, petitioners claimed a deduction for car and truck expenses in the amount of $5,600. They also claimed the same $5,600 on their amended 1993 return. Respondent has agreed that petitioners were entitled to $1,680 of the $5,600 claimed for car and truck expenses in 1993. In allowing $1,680 for car and truck expenses in both 1992 and 1993, the revenue agent based his conclusion on the number of trips from Rialto, California, to Abbey Road in Los Angeles, California. The agent testified that petitioners originally approximated that one trip per week was taken. After securing invoices from Abbey Road, which totaled 183 in 1992 and 188 in 1993,4 the agent estimated that two trips were taken per week, for a total of 100 trips per year. 3(...continued) any passenger automobile. 4 For 1993, 2� months of invoices were missing.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011