- 9 - payroll services, his payments to his only purported employee would not necessitate such services. Other than the BMS receipts, petitioner failed to produce any substantiation that he actually made payments to his father- in-law or BMS or that the purported payments actually related to a trade or business. Given the relationship between petitioner and the people who operated BMS, the fact that the payments were allegedly made in cash, and the fact that the receipts indicate that they were for payroll work that would seem unnecessary, we find that petitioner has failed to meet his burden of proof. Respondent’s determination disallowing petitioner’s claimed legal and professional expense deductions is sustained. 2. Rental Expenses Respondent argues that petitioner failed to substantiate the $2,400 rental equipment expense deduction because the invoices submitted by petitioner lack credibility and are generally untrustworthy. To substantiate his rental expenses, petitioner submitted five invoices from CB Associates indicating that he leased a laptop computer for $3,600 and a printer for $2,400 from January 7 to December 7, 2002, at monthly rates of $300 and $200 for the computer and printer, respectively.6 Craig Brown, 6 The invoice dates and amounts purportedly paid in 2002 are as follows: January 7-$500; April 7-$1,500; August 7-$2,000; November 7-$1,500; December 7-$500. The return address for CB Associates on the invoices was incorrect because it had the wrong (continued...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011