- 13 - truck and the trailer. The only documentary evidence petitioners submitted with respect to the purchase in question was a check dated January 7, 1994 (check), in the amount of $500 that was payable to Bledsoe Ford. The signature line on that check bore the name “Larry Petty”, and a notation on the check stated: “down on 93 F350". Petitioners contend that the check was for the purchase of the extended warranty on the truck and not for the purchase of the truck itself. On the record before us, we find that petitioners have failed to establish that they paid specified amounts of expenses during their round trip from Alaska to Texas, that any such amounts were paid in 1993, that any such amounts were for ordinary and necessary expenses paid in 1993 in carrying on any trade or business of Mr. Petty or petitioners, and that any such amounts were not already included as part of the expenses conceded by respondent. We further find on the instant record that petitioners have failed to establish their entitlement for 1993 to any deduction for depreciation under section 167(a) with respect to their purchase in Texas of a truck and a trailer. Based on our examination of the entire record before us, we find that petitioners have failed to prove that they are entitled for 1993 to deductions under sections 162(a) and 167(a) in excess of any such deductions conceded by respondent with respect to amounts that they claim they paid during their round trip fromPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011