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Tax Regs. Therefore, we cannot allow SCC deductions for these
expenses.
b. Automobile and Truck Expenses
SCC claims deductions for automobile and truck expenses for
1991, 1992, 1993, and 1994 of $686.56, $572.66, $27, and
$1,239.93, respectively. Respondent allowed SCC automobile and
truck expenses for only the years 1992 and 1994 of $469.35 and
$320.91, respectively. Respondent disallowed the remaining
automobile and truck expenses because of failure to substantiate
that the amounts were expended for business use. SCC did not
offer any evidence at trial or present any argument on brief
regarding these amounts. Accordingly, respondent’s determination
on these remaining items is sustained.
c. Utility and Telephone Expenses
SCC claimed utility expenses for the years 1991-94 of
$3,704.50, $3,314.11, $1,669.92, and $4,692.60, respectively.
Respondent concedes that SCC may deduct $3,609.20, $2,873.73,
$912.20, and $3,118.61, respectively for 1991-94. SCC has failed
to present any evidence to substantiate entitlement to the
remaining disallowed deductions. Accordingly, respondent’s
determination on these items is sustained.
In addition, SCC claimed telephone expenses for the 1992 tax
year of $665.53. Respondent concedes that SCC may deduct
$355.77. SCC failed to present any evidence at trial or present
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