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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.
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