- 17 - prepared both the partnership return and petitioners’ individual return, making it particularly difficult to construe either as corroboration for the other. Petitioners also point out that the combined financial report for LeBouef Company and LeBouef Company, Inc., contains an unaudited financial statement for Toro Leasing reflecting a line item of $104,747 for “Loss on disposal of fixed assets”. However, such statement again is merely a representation by management and falls far short of proving that specific business property was disposed of at a loss correlating to that shown on the Schedule K-1 and petitioners’ Form 4797. We simply lack any documentary evidence, such as receipts, bills of sale, or partnership books and records, to affirmatively establish that the items of business property listed on the partnership return were in fact acquired and sold at the amounts claimed. Hence, petitioners have failed to establish even that the purported loss was sustained by Toro Leasing. We hold that petitioners are not entitled to deduct the $19,791 reported on their Form 4797. V. Section 6651(a)(1) Addition to Tax Section 6651(a)(1) imposes an addition to tax for delinquency in filing returns and provides in relevant part as follows:Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
Last modified: May 25, 2011