- 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 Next
Last modified: May 25, 2011