- 24 - Expense 1994 1995 1996 Car & truck $3,840.61 –- $1,722.89 Travel 7,627.35 $6,669.83 3,752.40 Meals & ent. 385.39 1,385.75 306.31 Other: Parking 358.55 –- 190.40 Lodging –- 1,965.39 814.14 In support of these expenses, petitioners produced various receipts and statements purporting to show the actual expenditures. However, petitioners failed to produce credible evidence, if any evidence at all, as to the business purpose of each expense. Moreover, petitioners failed to introduce evidence establishing the business relationship to petitioner with any persons purportedly being entertained or using the facilities or property rented by petitioner. Petitioners’ evidence with respect to these expenses does not satisfy the stringent substantiation requirements of section 274(d). Moreover, as noted earlier, the Court cannot allow or estimate an allowable deduction for any of these expenses under the Cohan rule. Thus, the Court holds that petitioners are not entitled to deduct any of the claimed expenses for the years at issue in excess of what was allowed by respondent.8 8 As stated previously, respondent conceded that petitioners are entitled to deductions for meals and entertainment expenses (prior to the 50-percent limitation) totaling $112.45 for 1994. This amount will be taken into (continued...)Page: Previous 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 Next
Last modified: May 25, 2011