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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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