Roger L. and Geraldine Williams - Page 17

                                        -17-                                          
               At trial, petitioners introduced three checks payable to               
          "cash" totaling $2,285 to support the claimed deduction.8  Two              
          checks are dated February 1993 and one check is dated March 1993.           
          Petitioners contend that these checks are sufficient to                     
          substantiate the claimed deduction.  We disagree.                           
               A check made payable to "cash" does not, in and of itself,             
          prove payment of a deductible expense.  And, other than their own           
          self-serving testimony, petitioners offered no evidence in                  
          support of the claimed deduction.  See Wood v. Commissioner, 338            
          F.2d at 605; Niedringhaus v. Commissioner, 99 T.C. at 219-220;              
          Tokarski v. Commissioner, 87 T.C. at 77; Hradesky v.                        
          Commissioner, 65 T.C. at 90.                                                
               Thus, petitioners did not present a single invoice for                 
          either materials or services related to the alleged repair of the           
          existing shoeshine stand or the construction of the new stand.              
          Although petitioners claim that their records were destroyed by             
          fire,9 petitioners failed to explain why the alleged suppliers or           
          service providers (such as the "architect") were unable to                  
          testify on petitioners' behalf, or why the records of the alleged           
          suppliers or service providers were unavailable.                            



          8  According to petitioners, the $53 difference between the                 
          amount deducted ($2,338) and the sum of the three checks ($2,285)           
          represents the cost of transporting the new shoeshine stand to              
          SeaTac Airport.                                                             
          9  See supra note 4.                                                        




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