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Income Tax Regs.
In addition, a computer and peripheral equipment such as a
printer constitute “listed property” for purposes of section
274(d). Secs. 274(d)(4), 280F(d)(4)(A)(iv); see sec.
168(i)(2)(B). Accordingly, the stringent substantiation
requirements of section 274(d) apply.
The record in this case does not permit us to find that
petitioner even purchased a computer and printer in 2000, much
less its cost and the date placed in service. The only
documentary evidence that petitioner introduced was a one-
sentence letter on personal stationery from “Frank Anderson”,
which provided no detail whatsoever other than to assert that
petitioner purchased a computer and printer for $3,000 “for the
entire setup during the year of 2000.”
At trial, petitioner described herself as “computer
illiterate”. She stated that she had “no idea” what type of
software was installed on the computer, and she was totally
unfamiliar with any of the computer’s specifications. Indeed,
she was not even able to describe convincingly the use to which
the computer was supposedly put.
In view of the foregoing, we hold that petitioner failed to
satisfy her burden of proof. Accordingly, we sustain
respondent’s determination on this issue.
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Last modified: May 25, 2011