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Fuel Expenses
Petitioner claimed fuel expenses of $25,864, $17,982, and
$24,041, respectively, on his 1992, 1993, and 1994 Federal income
tax returns. In the notice of deficiency, respondent disallowed
a portion of the fuel expenses paid in each year-–$2,601 for
1992, $242 for 1993, and $4,528 for 1994. Respondent asserts
that petitioner failed to substantiate the actual payment of the
expense in some cases and the business purpose for the payment in
others. Petitioner’s documentation of his disallowed fuel
expenses, as described by respondent, included receipts for
unleaded gasoline and checks written to gas stations/convenience
stores with no receipts to indicate what, if anything, was
purchased. Petitioner did not offer the documentation into
evidence. Petitioner’s dump truck used diesel fuel, so we can
only conclude, based on respondent’s description of petitioner’s
documentation, that the receipts for unleaded gasoline related to
one of petitioner’s other vehicles.
Petitioner has failed to prove that he is entitled to fuel
expense deductions in excess of those allowed by respondent.
Meals
Petitioner claimed he paid $3,484, $1,965, and $1,222 for
business meals in 1992, 1993, and 1994, respectively, of which he
deducted $2,787, $1,572, and $611 after applying the applicable
percentage limitation of section 274(n). Because petitioner was
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Last modified: May 25, 2011