Gail Marie Harmon - Page 7




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          a note on a piece of paper listing $89 for “roto rooter”, $200              
          for “fence”, and $240 for “painting”.                                       
               We find all of the evidence produced by petitioner to                  
          substantiate the various rental expenses to be unreliable.                  
          Furthermore, petitioner has failed to provide a sufficient basis            
          upon which to estimate the expense amounts, despite her attempt             
          to reconstruct the expenses based upon available records.  We do            
          not find credible petitioner’s testimony that she hired someone             
          from the neighborhood to perform services for her on nearly every           
          visit she made to the properties, and that she paid all these               
          individuals in cash, never producing a written record of the                
          payment.  As for the few written records she did produce--                  
          primarily the sticky notes upon which her summary was based--the            
          records contained too little information and did not appear to be           
          contemporaneously maintained with the payment of the expenses.              
          We sustain respondent’s determination with respect to the rental            
          expenses.                                                                   
               Finally, to substantiate the disallowed miscellaneous                  
          itemized deductions, petitioner provided a summary listing                  
          various travel and transportation expenses.  Petitioner testified           
          that the expenses were incurred in travel to several different              
          investment properties.  We again find this to be unreliable                 
          evidence and to be insufficient substantiation, especially with             
          respect to those expenses subject to the strict substantiation              






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