- 18 - property includes any passenger automobile. Sec. 280F(d)(4)(A)(i). A taxpayer is required by section 274(d) to substantiate a claimed expense by adequate records or by sufficient evidence corroborating the taxpayer’s own statement establishing the amount, time, place, and business purpose of the expense. Sec. 274(d). Even if such an expense would otherwise be deductible, the deduction may still be denied if there is insufficient substantiation to support it. Sec. 1.274-5T(a), Temporary Income Tax Regs., supra. At trial, petitioners failed to substantiate any of the amounts claimed on the Schedules C that were disallowed in the notice of deficiency. The Court provided petitioners ample time to present evidence establishing the correctness of amounts claimed on the Schedules C. However, petitioners presented absolutely no evidence to establish that any of their documents corresponded directly to amounts claimed on the Schedules C. In addition, Mr. Nunn presented false invoices and testimony lacking credibility and truthfulness. Therefore, the Court was unable to apply the Cohan doctrine to the applicable items because there was no reasonable evidentiary basis to form an estimate of whether any of those items were allowable. Instead of providing evidence in an attempt to substantiate the amounts reported, petitioners chose to rely primarily onPage: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
Last modified: May 25, 2011