- 7 - than actual odometer readings. We find the summary of truck repairs and maintenance to be insufficient substantiation because the underlying records were not produced and because petitioners have not shown the percentage of business versus personal use of the truck as required by section 274(d). Finally, we find the summary of motorcycle costs to be insufficient substantiation because it was based solely upon recollection and was not supported by other reliable evidence. Because petitioners have not substantiated the amounts of the expenses in issue, we sustain respondent’s disallowance of the deductions therefor. To reflect the foregoing, Decision will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7
Last modified: May 25, 2011