- 10 -
checks reflecting payments of various phone bills and utilities
(marked for identification as Exhibit 12-P); (6) 15 pages of
telephone bills (marked for identification as Exhibit 13-P); and
(7) 17 pages of various receipts and charge card statements
purporting to show additional purchases with regard to repairs
and maintenance (marked for identification as Exhibit 14-P).
Many of these exhibits contained additional material written on
them by petitioners. Respondent filed an objection to
petitioners’ motion to supplement the record. In the main,
respondent’s objections go to the weight of the proffered
evidence and not to its admissibility. However, we sustain
respondent’s objection with regard to Exhibit 14-P as not being
responsive to the Court’s order and for lack of foundation. In
addition, none of the handwritten material will be considered, as
it is testimonial and not self-authenticating. Moreover, the
first seven pages submitted with petitioners’ cover letter we
consider as part of petitioners’ motion and not as documentation,
inasmuch as they are testimonial; they are not admitted.
With regard to a home office deduction for Mrs. Coffman, we
note that her testimony generally supports the conclusion that 9
percent of the home was used by her exclusively for her then
business entitled D.C. Enterprises, a dog-grooming and breeding
business. For 1995, she reported a net profit from that business
of $406. Section 280A(c)(5) requires the allocation of items
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011