Rick and Ruth Baime Richards - Page 20

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               Under section 280F(d)(4), petitioners’ truck is listed                 
          property and is subject to the stringent substantiation                     
          requirements of section 274(d).  See sec. 280F(d)(4)(A)(i), (ii),           
          (5)(A).  Petitioners must substantiate by adequate records the              
          four requirements of section 274(d).  See sec. 274(d); sec.                 
          1.274-5T(b)(6), (c)(1), Temporary Income Tax Regs., 50 Fed. Reg.            
          46016 (Nov. 6, 1985).                                                       
               While petitioners did retain receipts which indicate the               
          amount of each expenditure, petitioners have failed to show the             
          business and total usage of the truck.  Petitioners did not                 
          establish how they came up with the 80-percent figure, nor did              
          they maintain any logs or records on the use of their truck.                
          Based on this lack of evidence, we cannot find that petitioners             
          are entitled to a deduction for vehicle expenses.  Therefore,               
          respondent is sustained on this issue.                                      
               Office/Household Expenses                                              
               Petitioners claimed a deduction of $5,132 for “allowable               
          office/household expenses”.  This amount reflects 33 1/3 percent            
          of petitioners’ household expenses.  The household expenses                 
          consist of insurance, mortgage interest, utilities, cable                   
          television, pool service, yard service, home improvements, and              
          numerous expenses at retail stores.                                         
               Section 262 disallows any deduction for personal, living, or           
          family expenses, and included in this category is the expense of            

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