Darryl Shawn and Melonee Yevette Bundridge - Page 10

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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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