John Mosier and Sarah Spain - Page 9




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               Petitioners presented as evidence receipts for travel                  
          expenses for the writing/lecturing business in 1994.  However,              
          respondent’s concessions took into account this additional                  
          substantiation.  No evidence was presented for the travel                   
          expenses for this business in 1995.                                         
               Petitioners presented a credit card statement showing costs            
          relating to a Caribbean cruise, purportedly a travel expense                
          related to the travel/writing/consulting business.  However, they           
          failed to provide an adequate explanation as to how this expense            
          was a business expense, and in its absence we find instead that             
          it was a nondeductible personal expense.  Finally, petitioners              
          presented no evidence substantiating the deduction for “other               
          expenses” claimed for this business.                                        
               We sustain respondent’s determinations with respect to the             
          items at issue, as modified by the various concessions.                     
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   
               To reflect the foregoing,                                              
                                             Decision will be entered                 
                                        under Rule 155.                               













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