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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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Last modified: May 25, 2011