Neil T. Nordbrock - Page 14




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          petitioners for seminars totaled less than $500 and do not meet             
          that threshold.  The travel expenses claimed by petitioners were            
          not substantiated as required by section 274(d).  No                        
          contemporaneous documents or other reliable evidence corroborated           
          the alleged business purpose of the travel.                                 
               Petitioners contend that the repairs and maintenance expense           
          related to an office in their home.  The only evidence on this              
          issue is Mr. Nordbrock’s uncorroborated and conclusory testimony.           
          The documentation that was presented consisted of checks without            
          invoices and credit card charges, and the documentation showed no           
          allocation between an alleged office in the home and the personal           
          residential quarters of petitioners.  Petitioners failed to                 
          present reliable or persuasive evidence that would satisfy the              
          conditions of section 280A(c).                                              
               After examination of the documents submitted by petitioners            
          and petitioners’ testimony, we conclude that any additional                 
          expenses beyond those conceded by respondent are not adequately             
          substantiated.                                                              
               There is no excuse for petitioners’ failure to present                 
          substantiating materials during the administrative stages and for           
          more than a year while these cases were pending.  They                      
          disregarded the Court’s order that they produce documents for               
          1996 and 1997.  They are familiar with the consequences of                  
          failing to produce documents when required by law or Court order            






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