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7. Repair Expenses
Respondent determined that petitioner made an adjusting
entry in 1992 of $1,543 for repair costs for which no support was
provided. Consequently, respondent disallowed this amount.
Petitioner did not attempt to substantiate this amount and
presented no evidence at trial. Accordingly, petitioner is not
entitled to the $1,543 repair expenses disallowed by respondent.
Investment Tax Credit
Findings of Fact
During the period between 1984 and 1992, petitioner
purchased numerous pieces of equipment on which it claimed the
investment tax credit (ITC). During the period between 1984 and
1992, petitioner recaptured the ITC from the disposition of an
automobile that was sold on September 30, 1985. Petitioner’s tax
returns for the 1984 through 1992 tax years, however, reflect the
disposition of various pieces of equipment.
Discussion
A taxpayer who claims an ITC must maintain various records
establishing certain important facts pertaining to each item of
section 38 property for which an ITC has been claimed. Chief
among these records are those required to keep track of specific
details identifying ITC assets and their acquisition and
disposal. These records are required not only to verify the
amount of the credit taken but also to determine whether any ITC
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