Theodore Langworthy, Jr. - Page 13

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          miscellaneous car repairs (including parts).  Petitioner raced              
          the car approximately 10 times during each of the years in issue.           
          In support of his claimed deductions, petitioner provided his               
          return preparer, Mr. Dillon, with a summary listing of gasoline             
          and parts purchased during 1987 and 1988.  At trial, petitioner             
          produced no receipts for the race car expenses, which he                    
          generally paid in cash.  Respondent disallowed petitioner's                 
          deductions for race car expenses on the basis of petitioner's               
          failure to substantiate them.                                               
               3.   Truck Expenses--1990                                              
               During 1990, petitioner owned a 1976 Ford pickup truck which           
          he used in his business at the Bullfrog.  Petitioner used the               
          vehicle to pick up restaurant supplies, haul garbage to the dump,           
          drive to the bank, and drive drunk patrons home after the bar               
          closed at night.  Petitioner claimed truck expenses for the                 
          Bullfrog in the amount of $3,800.  Respondent disallowed                    
          petitioner's deduction for truck expenses on the basis of                   
          petitioner's failure to substantiate the claimed expenses.                  
                                       OPINION                                        
          I.   Period of Limitations and Fraud                                        
               The deficiency notice in the instant case was sent on April            
          1, 1996, after the expiration of the usual 3-year period of                 









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