Jack C. Goins, Sr. and Edith M. Goins - Page 9




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          food service), hotel, coffee breaks, clerical assistance, gas,              
          parking, repairs, telephone, postage, laundry, gifts, supplies,             
          and medical.  The total amounts of these expenses form the basis            
          for the deductions claimed by petitioner on the Schedules C for             
          1993 and 1994.                                                              
               According to petitioner, he only claimed deductions for                
          meals and lodging while he was traveling away from Frankfurt to             
          conduct an audit.  Comparing petitioner’s travel log to various             
          credit card receipts indicates otherwise.  On numerous dates in             
          1993 and 1994, the receipts indicate that petitioner was in                 
          Frankfort, while petitioner’s travel log indicates that                     
          petitioner incurred (and apparently deducted) expenses for one or           
          more meals.  At trial, petitioner testified that on weekend                 
          travel days he might be in Frankfort for some portion of the day            
          and in the city where the audit was being conducted for the                 
          remaining portion.  His explanation might cover some of the                 
          occasions, but many of the receipts indicate that petitioner was            
          in Frankfort on a day during the work week.  Under the                      
          circumstances, we are unwilling to accept petitioner’s log as               
          adequate substantiation for the traveling expenses deducted on              
          the Schedules C.                                                            
               Nor do petitioner’s receipts provide adequate substantiation           
          of the traveling expense deductions claimed on the Schedules C.             
          The lodging receipts do not total anywhere near the amount                  






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