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rather than on the corporation’s return. We note that a
corporation is a separate legal entity, and an individual
generally may not claim deductions for expenses incurred by a
corporation. See Gantner v. Commissioner, 91 T.C. 713, 725
(1988), affd. 905 F.2d 241 (8th Cir. 1990). However, we need not
decide whether the deductions were those of the corporation (or
possibly employee business expenses) because we hold that
petitioners have not substantiated the expenses.
The evidence provided to support the deductions for the
expenses in issue is comprised of a summary showing mileage for
pickup and delivery of motorcycles, a summary of repairs and
maintenance on a truck, and a summary showing the costs
associated with a motorcycle for which petitioners claimed
depreciation expenses. All of the other evidence provided by
petitioners, as well as their testimony, helps to establish that
they were involved in the business of Olray Corporation but does
not provide adequate substantiation of any specific expenses.2
We find the mileage summary to be insufficient
substantiation under section 274(d) because the mileage amounts
were not entered at the time the vehicle was used and because
they were based on figures in a computer atlas database rather
2Petitioners filed an amended Federal income tax return for
taxable year 1996, but the return was not accepted by respondent.
This return, which was introduced as evidence, merely contains
uncorroborated assertions by petitioners and does not provide
substantiation for any of the amounts in issue.
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