- 20 - allowed for, among other things, traveling expenses, entertainment expenses, meal expenses, and expenses with respect to listed property (as defined in section 280F(d)(4) and including passenger automobiles) “unless the taxpayer substantiates by adequate records or by sufficient evidence corroborating the taxpayer’s own statement”: (1) The amount of the expenditure or use; (2) the time and place of the expenditure or use; (3) the business purpose of the expenditure or use; and (4) in the case of entertainment, the business relationship to the taxpayer of the persons entertained. Sec. 274(d). On their Schedules C, petitioners claimed amounts for car and truck expenses, depreciation and section 179 expense, insurance, legal and professional services, office expenses, rent, repairs and maintenance, taxes and licenses, and other expenses (including continuing education, professional dues, parking, telephone, group insurance, books and periodicals, drugs and medications, and supplies). Respondent’s requests for admission contained the following paragraphs on this issue: “Petitioners have presented no evidence to substantiate any of their claimed deductions on their 1996 Schedule C”; “Petitioners have presented no evidence that any of their claimed deductions on their 1996 Schedule C were ordinary and necessary businessPage: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
Last modified: May 25, 2011