- 6 - Petitioners are not entitled to estimate deductible car and truck expenses without the substantiation of time, place, and business purpose required by section 274(d). See also section 280F(d)(4) with respect to expenses relating to passenger automobiles. Despite the volume of paper presented by petitioners, they have failed to satisfy the strict substantiation requirements of the applicable law. Even if we could accept Mr. Jacobsen’s generalized testimony and assertions that all of the mileage related to attempts to secure business and to make contacts, the amount is unreasonable in view of his testimony about the severity of Mrs. Jacobsen’s illness during 1997. On this record, no deduction for car and truck expenses or meals and entertainment expenses may be allowed. Legal Expenses Respondent contends that there is no evidence substantiating petitioners’ claim that they incurred legal expenses during 1997 that were deductible as business expenses. Again, petitioners presented fragmentary documents that showed that certain payments were made. Neither the documents nor Mr. Jacobsen’s testimony adequately or persuasively explained how the expenses related to his business. His testimony about the various matters discussed with regard to the services provided by the lawyer to whom payment was made suggests items that are not currently deductible. Mr. Jacobsen testified:Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011