Debra D. McNair - Page 12

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          establishing the amount, time, place, and business purpose of the           
               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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