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Respondent determined deficiencies in petitioners’ Federal
income taxes of $6,004.02, $8,561.18, and $7,701 for the taxable
years 1995, 1996, and 1997.
The sole issue for decision is whether petitioners have met
the strict substantiation requirements of section 274(d) with
respect to certain automobile expenses.
Some of the facts have been stipulated and are so found.
The stipulations of fact and the attached exhibits are
incorporated herein by this reference. Petitioners resided in
Oconto Falls, Wisconsin, on the date the petition was filed in
this case.
Fredrick J. Marquardt (petitioner) is in the business of
selling health and life insurance policies door-to-door in rural
areas of Wisconsin. With respect to this business, during 1995,
1996, and 1997, petitioner did not record on a daily basis either
his mileage or the names of customers he visited, nor did he
record the specific business purpose for each of his trips.
Petitioners reported the following amounts of mileage on
Schedules C, Profit or Loss From Business, in each respective
year:
1995 1996 1997
Business 54,238 78,985 64,638
Commuting 3,790 8,128 7,960
Other 3,214 1,104 1,708
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Last modified: May 25, 2011