Danielle L. Clark-Hernandez - Page 17




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               5.  Office Expenses                                                    
               Petitioner deducted office expenses of $4,829, $8,535, and             
          $9,308 in 1991, 1992, and 1993, respectively.  Respondent allowed           
          $2,758, $2,195, and $1,451, respectively.                                   
               At trial, however, petitioner produced a melange of receipts           
          that did not substantiate her claimed office expense deductions.            
          Petitioner attempted to substantiate the claimed office expenses            
          by submitting check receipts and canceled checks drawn on                   
          Dustbusters checking account and petitioner’s personal checking             
          account, and credit card statements.  Of the receipts presented,            
          petitioner testified that she counted only items on the receipts            
          that were related to her office.  In arguing that the expenses              
          were personal in nature rather than related to petitioner’s                 
          business, respondent notes that the receipts included amounts for           
          union dues associated with her W-2 jobs, Audubon print books,               
          snacks for the office, medication, vodka and wine, kitchenware,             
          dance/exercise clothing, Guess brand apparel, floral                        
          arrangements, groceries, hair accessories, blankets, pillows, and           
          wallpaper.  In some instances, receipts were duplicated in the              
          same year or in subsequent years.  Notations, if any, on the                
          checks submitted were vague.  In addition, some checks were                 
          simply made out to “cash” with no notation on the bottom that it            
          was for a deductible business expense.                                      
               Finally, on brief petitioner cites to “Treas. Reg.                     






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