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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.
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Last modified: May 25, 2011