- 12 - documents show that petitioners were involved in various investments, lawsuits, bankruptcies, and other legal matters, but they do nothing to substantiate specific deductible expenses. The documents which do show specific expenditures are with respect to the attorneys and the court reporting services noted above. Petitioners first argue that they are entitled to deduct additional expenses paid to Mark Kirby and Brian Upchurch in 1995, and to Matthew Martin in 1996. We hold that petitioners are not entitled to these deductions because they have failed to substantiate the payment of these expenses during the relevant years. Sec. 6001; sec. 1.6001-1(a), (e), Income Tax Regs. Petitioners next argue that they are entitled to deduct additional expenses paid to the two court reporting services, Janet Brown, and Brian Upchurch in 1996, and to Kirk Osborn in 1996 and 1997. A portion of these expenses was incurred in connection with the secondary malpractice suit brought by petitioners. The suit underlying the original malpractice claim by petitioners dealt with several issues, including petitioners’ personal bankruptcy and their investment in Tara. Because the connection between petitioners’ investment in Tara and the secondary malpractice suit years after Tara’s existence is too attenuated to ascertain; we are unable to estimate the portion of these expenses which may be deductible versus the portion whichPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011