- 14 - 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 orderPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011