Juan N. and Miriam J. Villareal, et al. - Page 16

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          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.                                   






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