George H. Richards - Page 20




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          the substantiation and election requirements of section 179 and             
          general substantiation requirements.                                        
               Although petitioner produced many receipts reflecting                  
          purchases of computer equipment, all receipts except one reflect            
          a subsequent tax year and cannot be used to substantiate                    
          purchases of property for 1997.  The one receipt from 1997                  
          indicates a purchase of computer equipment of $32.09.                       
               Petitioner failed to maintain records reflecting the cost of           
          the computers, the use of the property, the date of the use, the            
          business purpose of the property, from whom the equipment was               
          acquired, and when the computer equipment was placed in service,            
          as required by section 1.179-5(a), Income Tax Regs.  In addition,           
          petitioner’s amended return was dated May 15, 2000, and filed               
          sometime thereafter.  Petitioner’s 1997 return was due on April             
          15, 1998, so the amended return was not timely filed.                       
          Accordingly, petitioner is denied the deduction for his computer            
          equipment.                                                                  
                    C.  Expenses From Business Use of Home                            
               Petitioner deducted depreciation of the marital home, a                
          casualty loss, mortgage interest, real estate taxes, insurance,             
          and utilities in connection with the business use of his home on            
          Form 8829, Expenses for Business Use of Your Home, attached to              
          his return.                                                                 








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