Mary T. King and Fatai O. King - Page 10




                                        - 10 -                                          
             for all of their personal travel.  In support of their                     
             claim to be entitled to deduct car expenses in connection                  
             with their newsstand business of $2,132, they sought the                   
             introduction of three repair invoices and a handwritten                    
             sheet purporting to show gasoline purchases in cash.  Two                  
             of the repair invoices in the amounts of $817.20 and                       
             $149.25 were paid in 1992 and do not have any apparent                     
             connection to 1993.  They were not accepted into evidence.                 
             The third repair invoice is in the amount of $273.42, but                  
             there is no testimony or other evidence in the record to                   
             show the relationship of the expenditure to petitioner’s                   
             newsstand business as opposed to petitioners’ personal use                 
             of the car.  Finally, petitioners have not substantiated a                 
             deduction for gasoline purchases of $892.  Petitioners                     
             introduced a handwritten list entitled “car gas purchases”,                
             and petitioner testified that it is a list of the weekly                   
             cash expenditures “on the gas for traveling from the                       
             newsstand to the warehouse”.  There are 61 entries of even                 
             dollar amounts listed on the sheet that total $876, rather                 
             than $892.  There are no dates on the list and no                          
             indication of mileage.  There is no way to determine what                  
             portion of the alleged gasoline purchases was used for                     
             business and what portion was for petitioners’ personal use                
             of the car.  Thus, petitioners have not substantiated any                  






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