- 7 - is allowable (1) for traveling expenses, (2) for entertainment expenses, (3) for expenses for gifts, or (4) with respect to listed property. Listed property includes passenger automobiles and other property used as a means of transportation. Sec. 280F(d)(4). To meet the strict substantiation requirements, the taxpayer must substantiate the amount, time, place, and business purpose of the expenses. Sec. 274(d); sec. 1.274-5T, Temporary Income Tax Regs., 50 Fed. Reg. 46006 (Nov. 6, 1985). Petitioners presented evidence of numerous credit card interest payments made during the years in issue, purportedly in connection with the writing/lecturing business. They dispute respondent’s determination of the percentage of these expenses that was business rather than personal. However, they did not provide the Court with a more reliable method of ascertaining the correct percentage, and they did not otherwise show more interest to be deductible than that which was determined to be so by respondent. Petitioners presented no evidence to substantiate the claimed itemized deductions. They testified that some of their substantiating documents had been destroyed when repair work had been done on or around their condominium apartment. However, petitioners did not provide the Court with any reliable method by which we could estimate any deductible expenses.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011