Shawn M. and Debra E. Swagler - Page 15

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          these records what types of items petitioners purchased.                    
          Additionally, other than handwritten notations on some of the               
          receipts and cash register tapes, petitioners failed to offer any           
          evidence linking any of the expenses to the rental properties.              
          The Court holds that petitioners offered no evidence that                   
          supports deductions in excess of the amounts allowed by                     
          respondent.  Therefore, the Court sustains respondent on this               
          issue.                                                                      
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   
                                             Decision will be entered                 
                                        for respondent.                               


























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