- 11 -
of the alleged expenditures as required by section
274(d)(1).
In their amended return, petitioners claim insurance
expenses in the aggregate amount of $1,000. At trial,
petitioners introduced copies of four checks totaling
$593.70. Three of those checks in the aggregate amount of
$382.70 were payable to Flagship Insurance Co. Petitioner
testified that those checks were for insurance on
petitioners’ newsstands but petitioner also acknowledged
that he maintained homeowner’s insurance on his residence.
There is nothing in the record, other than petitioner’s
vague testimony, to show that the subject expenditures in
the aggregate amount of $382.70 were for insurance on the
newsstands. Petitioners introduced no documents to
corroborate Mr. King’s testimony, such as invoices or
insurance polices. Accordingly, we agree with respondent
that the expenditures reflected by the three checks in the
aggregate amount of $382.70 are not deductible. The fourth
check in the amount of $211 is payable to Pennsylvania Auto
Insurance Plan. The expenditure reflected by this check
appears to be for insurance on petitioners’ automobile. It
is not an allowable expense because petitioners have
provided no way to allocate the expenditure between their
personal and business use of the automobile, and, thus,
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011