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arguendo that he did in fact have a trade or business, we hold
that he is not entitled to the claimed deductions (or to the cost
of goods sold) because they have not been substantiated. See
secs. 274(d), 6001. Petitioner claimed that flooding destroyed
his records, but provided neither corroboration of this assertion
nor any reconstructed records. Furthermore, petitioner’s
testimony--the only evidence he provided--was vague concerning
specific items and did not provide a sufficient basis upon which
we could estimate any amounts.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
Decision will be entered
for respondent.
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