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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 from
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