- 15 - 1995. Respondent disallowed the $112,413 and $131,014 deductions for 1993 and 1994, respectively, on account of a lack of substantiation as well as petitioners’ failure to establish that the expenses were ordinary and necessary. At trial, petitioner failed to present any evidence, documentary or otherwise, to substantiate the claimed supply expenses. Consequently, we sustain respondent’s position on this issue. 3. Returns and Allowances for 1995 Petitioner claimed Schedule C returns and allowances for the tax year 1995 in the amount of $454,387. Respondent disallowed the deduction and adjustment on account of petitioner’s lack of substantiation. Again, at trial, when asked if he had anything to substantiate his returns and allowances for 1995, petitioner stated “I just don’t have a thing.” Petitioner presented no evidence to substantiate entitlement to the amounts claimed. Again, we must sustain respondent’s determination on this issue. 4. Conclusion Petitioners failed to substantiate any of the amounts claimed on the Schedules C that were disallowed in the notice of deficiency. Instead of providing documentary evidence to attempt to substantiate the amounts claimed, petitioner chose to rely solely on his testimony. Petitioner did not call as witnesses thePage: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
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