- 19 -
do not conclude that petitioners established that these expenses
were for anything other than “personal, living, or family”
purposes. See sec. 262(a). As concluded above, Mr. Evan was not
in a trade or business as a professor or real estate broker
during the years in issue. Mr. Evan was the primary caregiver
for his youngest children during the years in issue. As a
result, we conclude that the reported expenses for 1997 have not
been sufficiently substantiated and hold that petitioners are not
entitled to deductions for these expenses for 1997.
As noted above, the parties provided no summaries as to the
expenses reported for 1998, and petitioners provided no further
substantiation of these expenses on the record. Therefore, we
also hold that petitioners are not entitled to a deduction for
these expenses for 1998.
In reaching our holdings herein, we have considered all
arguments made, and, to the extent not mentioned above, we
conclude that they are moot, irrelevant, or without merit.
To reflect the foregoing,
Decision will be
entered for respondent.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19
Last modified: May 25, 2011