Alan D. Lenzen and Dianne Lenzen - Page 8

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               Next, petitioners have not shown that they fulfill the                 
          requirements of section 7491(a)(2).  RAF has not shown that it              
          meets the net worth requirement of section 7491(a)(2)(C).  In               
          addition, petitioners have not shown that they complied with the            
          Code’s substantiation requirements.  Petitioners argue that they            
          did not provide substantiation to the revenue agent in RAF’s                
          audit because he did not specifically request substantiation of             
          the disallowed corporate card items.  However, under section                
          7491(a)(2)(A), petitioners must show that they complied with the            
          Code’s substantiation requirements in general, not simply in                
          response to an audit.  The charges at issue include those made at           
          restaurants, hotels, airlines, gas stations, clothing stores, and           
          general retail stores.  Petitioners provided credit card                    
          summaries of these charges, showing only the vendor, the type of            
          services offered by the vendor, e.g., “Gas/Misc” and “Food/Bev”,            
          and the amount of the charge.  These summaries do not provide the           
          substantiation required by section 274 for entertainment and                
          travel expenses, such as the date and business purpose of each              
          expense and the business relationship to the person being                   
          entertained.  The statement summaries also do not satisfy the               
          substantiation requirement under section 162 that a taxpayer who            
          is related to his employer under section 267(b) keep sufficient             
          records “to enable the Commissioner to correctly determine income           







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