Kevin and Bridget Naughton - Page 20




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          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 business               










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