Marian Wilson - Page 10

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          documentation is insufficient to substantiate the claimed                   
          expenses.  See Hradesky v. Commissioner, supra at 90.                       
               Petitioner testified that she and her sisters used                     
          petitioner's automobile for both Special Occasions and Special O.           
          In addition, petitioner admitted that she also used her                     
          automobile on behalf of other businesses, as well as for personal           
          use.  Petitioner failed to establish the percentage of personal             
          automobile use versus business automobile use.7  Under such                 
          circumstances, any attempt on the part of this Court to estimate            
          petitioner's purported automobile expenses would amount to little           
          more than guesswork.                                                        
               On the basis of the record, we find that petitioner has                
          failed to establish that either Special Occasions or Special O              
          incurred any deductible automobile expenses for the years in                
          issue.  Additionally, we find that petitioner has failed to                 
          establish any amount of automobile expenses for the years in                
          issue and is therefore not entitled to treat such purported                 
          expenses as capital contributions.                                          
               The parties stipulated that petitioner had a zero basis in             
          Special Occasions as of January 1, 1992.  Because Special                   
          Occasions did not maintain written records which were accurate              
          enough to determine petitioner's bases for the 1991, 1992, and              

          7    Additionally, petitioner failed to establish what percentage           
          of business use reflects use of the automobile on behalf of                 
          Special Occasions, Special O, Klyce, or Sweets.                             

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