- 13 - any documents to support his vague and illusory testimony. We sustain respondent’s determination. 4. Commissions and Fees Petitioner deducted $1,194 for commissions and fees. At trial, petitioner testified that he paid clients referral fees for new clients. Petitioner did not present any documents or other evidence as to this deduction. Petitioner failed to provide the Court with evidence sufficient to establish a rational basis upon which an estimate can be made. We sustain respondent’s determination. 5. Depreciation Petitioner deducted $2,403 for depreciation. Petitioner did not attach a Form 4562, Depreciation and Amortization, to his Federal income tax return. At trial, petitioner submitted a list entitled “Schedule C Depreciation”. Petitioner depreciated two computers, a laser printer, a calculator, a fax machine, various pieces of furniture, and a Mercedes. For the reasons previously stated, petitioner is not entitled to a depreciation deduction for his Mercedes. Of the items listed on the schedule, only some of the furniture and one of the computers, an Apple Macintosh LC III, were purchased in 1994. A computer is a listed property under section 280F(d)(4)(iv), and a taxpayer must meet the strict substantiation requirements of section 274(d). PetitionerPage: 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