Michael R. and Sheila Olsen - Page 7




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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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