William and Shirley Pratt - Page 15




                                       - 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 the          






Page:  Previous  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  21  22  23  Next

Last modified: May 25, 2011