- 18 - evidence at trial and presented only legal arguments to the Court. As noted above, because of the fire in petitioners’ residence and the damages that resulted, the parties stipulated summaries of information provided by petitioners during respondent’s audit to support the claimed expense deductions reported for 1997. The parties did not stipulate any summaries for 1998. We find that the summaries are inadequate to substantiate the claimed deductions. For example, we find petitioners’ use of the same mileage and parking fee for each school visited and their claim that they visited each school in alphabetical order implausible. Also, as support for the travel expenses, petitioners provided, for the most part, their own written and oral testimony. For the few receipts that were provided for the trips (most notably, two trips to Florida taken in mid-March and late December), petitioners offered only testimony that the trips were for the purpose of job-hunting or continuing education. We find that petitioners’ proffered testimony does not qualify as reasonable secondary evidence to replace that required by the stringent record-keeping rules of section 274(d). Petitioners argue that these expenses were necessary for Mr. Evan to maintain and improve his skills as a professor and to keep his real estate license active, a requirement for teaching real estate and appraising. Although, according to the summaries, petitioners did provide receipts for some expenses, wePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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