Wing Y. Kwan - Page 6

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          said:  “They can mail it to your office.”  Petitioner also                  
          admitted that “I didn’t do a lot of travel business.”  Yet, he              
          provided a reconstructed mileage log prepared for the auditor               
          with 44 purported trips for “Sun Trips Pick up ticket”.  He had             
          no original records from which he prepared this reconstruction.             
          The mileage between petitioner’s address in San Francisco and Sun           
          Trips’s address in San Jose is 46.8 miles, so the 120 mile round            
          trips on the so-called log are overstated in any event.                     
          Respondent states that petitioner was allowed 44 trips for 94               
          miles and a miscellaneous deduction for other mileage.  We                  
          believe respondent was generous.  For the other mileage,                    
          petitioner relied essentially on his own testimony as to the                
          business purpose of these alleged expenses, as well as for the              
          other expenses in issue.  It is well established that this Court            
          is not bound to accept a taxpayer’s self-serving, unverified, and           
          undocumented testimony.  Tokarski v. Commissioner, 87 T.C. 74, 77           
          (1986); Hradesky v. Commissioner, 65 T.C. 87 (1975), affd. 540              
          F.2d 821 (5th Cir. 1976).  We find petitioner’s testimony to be             
          just that, self-serving, unverified, and undocumented.  We agree            
          with respondent that petitioner did not prove that the disallowed           
          car and truck expenses represent ordinary and necessary business            
          expenses or that such expenses were paid in 1998.                           
               The depreciation/section 179 issue turns on petitioner’s               
          claims relating to the purchase of a computer and computer                  






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