- 16 -
substantiation for these expenses other than the transaction
reports prepared by Mr. Tijerina's firm.
If petitioners incurred legal and professional services
expenses from other firms, the record does not show that
petitioners attempted to contact the providers of such services
in an attempt to substantiate petitioners' deductions.
We find that this Court does not have a reasonable
evidentiary basis by which to estimate petitioners' claimed legal
and professional services expense deductions. We therefore hold
that petitioners are not entitled to claim any legal and
professional services expense deductions for the 1994 tax year.
i. Tax and Licenses
Petitioners claimed tax and license expense deductions in
the amount of $305 on Schedule C of their 1994 Federal income tax
return. Most of these expenses would have been recorded by
Government departments or agencies, and yet the record does not
show that petitioners attempted to contact any of the agencies
involved in an attempt to substantiate petitioners' claimed
deductions.
On the basis of the record, we find that petitioner has
failed to provide a reasonable evidentiary basis to substantiate
their tax and license expense deductions. Accordingly, we hold
that petitioners are not entitled to claim tax and license
expense deductions for the 1994 tax year.
Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 NextLast modified: May 25, 2011