John Mosier and Sarah Spain - Page 8




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          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.                            








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