Robert A. Inzano and Martha O. Chavez - Page 7

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          granted, and the case was recalendared for September 22, 1997.              
          Finally, the case was continued from that date and recalendared             
          for January 26, 1998.  The Court notes that the only records                
          obtained by petitioners during this entire period and submitted             
          in evidence were 15 canceled checks for the period June 26, 1990,           
          through July 12, 1990.                                                      
               a.  Advertising.  Petitioner testified that JDB did                    
          extensive advertising by flyer and in the “Yellow Pages” of the             
          telephone book.  Considering the nature of the business, we are             
          surprised by this claim, in that petitioners’ clients were real             
          estate developers and not the general public.  Moreover, it would           
          have been a simple task to contact the telephone company or                 
          printers to obtain verification of their claimed advertising                
          expense.  On this record, we cannot allow any amount for                    
          advertising.                                                                
               b.  Car and truck.  Petitioner claimed that they had two               
          vehicles solely for business, in addition to petitioner wife’s              
          personal auto, which was used for nonbusiness purposes.  However,           
          no records were ever maintained for the vehicles’ usages, no                
          records were kept for the actual expenses incurred for these                
          vehicles, and no evidence was submitted regarding their cost.               
          Accordingly, because there is no compliance with the requirements           
          of section 274(d), no amount can be allowed for car and truck               
          expense.                                                                    





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