Darryl Shawn and Melonee Yevette Bundridge - Page 11

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               Petitioners argue that the deduction for car and truck                 
          mileage should be based on 183 trips in 1992 and 188 trips in               
          1993, because of the number of invoices.  They point to the                 
          testimony of Mr. Ginsburg, the custodian of records at Abbey                
          Road, who stated that the invoices contained language that the              
          merchandise was purchased and picked up in Los Angeles.  However,           
          petitioners did not provide any evidence (such as a diary or log)           
          to corroborate the number of trips that occurred.                           
               Petitioners did not maintain any records (such as an account           
          book, diary, log, or trip sheets) to substantiate the claimed               
          mileage expense deductions.  Petitioners failed to substantiate             
          the mileage expenses by adequate records.  Sec. 1.274-                      
          5T(c)(2)(i), Temporary Income Tax Regs., 50 Fed. Reg. 46017 (Nov.           
          6, 1985).  They also failed to substantiate the mileage expenses            
          by other sufficient evidence.  Sec. 1.274-5T(c)(3)(i), Temporary            
          Income Tax Regs., 50 Fed. Reg. 46020 (Nov. 6, 1985).                        
          Consequently, petitioners are not entitled to the claimed car and           
          truck expenses in excess of the $1,680 in 1992 and the $1,680 in            
          1993 conceded by respondent.                                                


          Issue 3.  Cost of Goods Sold (Supplies)                                     
               Cost of goods sold is subtracted from gross receipts from              
          sales to determine gross income from sales.  Sec. 1.61-3(a),                
          Income Tax Regs.  The cost of goods purchased for resale is                 





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