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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.
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