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the amount of car and truck expenses, the Court declines to
consider this evidence due to lack of credibility.
The Court holds that petitioner’s car and truck expenses
were not properly substantiated under the cited legal authority.
Petitioner, therefore, is not entitled to deductions in excess of
amounts allowed by respondent for car and truck expenses.
With respect to the amount deducted for cellular phone
expenses, petitioner presented no additional receipts showing he
was entitled to a deduction in excess of what was allowed by
respondent. In addition, petitioner offered no evidence
substantiating the purchase of a computer for use in his
business. Because cellular phones and computers are listed
property under section 280F(d)(4)(A), section 274(d) applies.
Petitioner did not meet the strict substantiation requirement of
section 274(d). These two expenses, therefore, are not allowed.
Finally, petitioner claimed expenses for supplies, uniforms,
and furniture in excess of the amounts respondent allowed.
Petitioner presented copies of canceled checks as the only
evidence in support of these expenses. In light of petitioner’s
inadequate record keeping and questionable credibility, the Court
declines to accept this evidence. Therefore, respondent is
sustained.
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Last modified: May 25, 2011