- 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 business
Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 NextLast modified: May 25, 2011