Kenneth and Sheila Smith - Page 9

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          opening brief, petitioners take the position that only the 1989             
          Southwind motor home was used in connection with Tracstar's                 
          business.                                                                   
               Based on the record, we find that petitioners have not                 
          substantiated with adequate records the extent, if any, that                
          their motor homes were used for business purposes during 1994.              
          We refuse to rely on petitioner's self-serving testimony of the             
          alleged business use of the motor homes because it is not                   
          corroborated by any other individual's testimony or any written             
          records of business use.  Niedringhaus v. Commissioner, 99 T.C.             
          202, 219-220 (1992); Tokarski v. Commissioner, 87 T.C. 74, 77               
          (1986).  Other than petitioner's uncorroborated testimony, the              
          only evidence of any business use of the motor homes is several             
          photographs.  We find these photographs unreliable because they             
          do not reveal when they were taken and do not identify the motor            
          home pictured.  We hold that petitioners are not entitled to                
          interest and depreciation deductions for business use of their              
          motor homes.7                                                               
               To reflect the foregoing,                                              


                                                  Decision will be entered            
                                             under Rule 155.                          

          7         Respondent concedes that petitioners are entitled to an           
          additional qualified residence interest deduction in the amount             
          of $5,579 for interest paid with respect to the motor homes                 
          during 1994.  See supra note 2.                                             




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