- 21 - store, and various food vendors (e.g., Domino’s Pizza and Arby’s). 4. Supplies Petitioner seeks to deduct unagreed expenses allegedly incurred in purchasing “supplies” for his aviation activities in 1989, 1990, and 1991. The “supplies” allegedly purchased include, among other things, grass seed, snacks (e.g., peanuts, candy, soft drinks), loofa sponges, toothpaste, mouthwash, soap, light bulbs, tools, sporting goods items, a shower curtain, batteries, miscellaneous items from auto parts stores, liquor, and clothing. Petitioner contends that some of the alleged purchases were made with cash. For these items, there is no corroborating documentation. To substantiate other items, petitioner has entered into evidence various receipts, credit card statements, canceled checks, and a check register. None of these documents directly establish business purpose. Petitioner seeks to fill these evidentiary gaps with his own self-serving testimony, which we do not find credible or reliable.12 On the basis of our review of all the evidence, we conclude and hold that petitioner has failed to adequately substantiate the amounts or business purposes of his alleged supplies 12 Petitioner’s documentary evidence includes cash register receipts from retail department or hardware stores listing numerous purchases in generally small amounts. Petitioner purported to recall with great specificity the circumstances and business purpose of individual, small-dollar items on these decade-old receipts. We did not find his testimony credible.Page: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Next
Last modified: May 25, 2011