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establishing the amount, time, place, and business purpose of the
expense.
Since petitioner has conceded that the Schedules C to her
1999 and 2000 tax returns as filed were filled with errors, we
will not address the items from those original returns and will
instead review whether petitioner is entitled to the revised
items reported on the draft amended returns, on which she relied
at trial.
For 1999, petitioner admitted that she underreported
receipts on her amended Schedule C by $400, and we hold that her
gross receipts are increased by this additional amount. With
respect to the deductions she claimed on her draft amended 1999
Schedule C, petitioner produced a very limited amount of
supporting evidence. Regarding her mileage deduction, petitioner
testified that she drove to various training seminars and
meetings with business contacts, and she produced photocopies of
calendar entries to document dates, places and purposes of those
trips. The handwritten calendar entries show that petitioner
traveled to St. Louis, Milwaukee, Detroit, and Toledo to attend
courses in word processing and other document-production
programs, civil litigation, legal writing, and electronic
billing. Petitioner did not produce certificates of attendance
or receipts showing payment for these courses. In the absence of
sufficient substantiation, particularly in light of the strict
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