Nicholas M. Romer - Page 21




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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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