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attached to the 1997 return and which summarized the various
items claimed thereon as section 179 expenses and depreciation.
These items were a 1994 Dodge truck, 1992 Dodge truck, van, file
cabinet, computer cabinet, fax machine, van engine, and cargo
trailer, and tools. No supporting documentation was provided
showing when these items were purchased, what their cost or other
basis was, or how the items were used in petitioner’s business.
At trial, petitioner failed to provide any testimony regarding
these or other substantiating details.
With respect to the car and truck expenses, petitioner
testified that the vehicles for which he claimed the deductions
were used solely for business purposes, and that he had other
vehicles which he used for personal purposes. He also partially
relied upon the same reconstructed travel summary discussed
supra. However, petitioner provided no substantiation of the
amounts, times, places, and business purposes of the car and
truck expenses as required by section 274(d), such as a
contemporaneous mileage log.
At trial, petitioners did not address specifically, and did
not provide substantiation for, the disallowed rent expense
deduction for 1996.
Petitioners briefly addressed the adjustments made to the
contract labor expense deductions in each year in issue. A
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