- 6 - 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 substantiationPage: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011