W. Bradford Davis and Tedde M. Rinker - Page 10

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          Temporary Income Tax Regs., 50 Fed. Reg. 46022 (Nov. 6, 1985),              
          which allow taxpayers to reasonably reconstruct their business              
          expenses when original documents are lost or destroyed through no           
          fault of the taxpayers.                                                     
               Respondent argues that petitioners failed to present                   
          credible evidence to substantiate that they incurred business               
          expenses in excess of the amount allowed by the notice of                   
          deficiency, and that petitioners have not provided the Court with           
          a sufficient basis on which to make a Cohan estimation.  Also,              
          respondent argues that several of the claimed deductions were for           
          nondeductible, personal expenses.  Finally, respondent argues               
          that petitioners have not met the heightened substantiation                 
          burden imposed by section 274 for those deductions to which                 
          section 274 applies.                                                        
               At trial, petitioners managed to produce a smattering of               
          canceled checks, receipts, and other records from 1999.                     
          Petitioners also presented exhibits containing reconstructions of           
          various categories of expenditures for 1999 that Dr. Rinker made            
          with the computer program Quicken (Quicken reports).  In their              
          testimony, petitioners related to the Court their memories of               
          their financial activities during 1999, the transactions                    
          underlying the source documents, and the way they arrived at the            
          amounts contained in their 1999 return and in the exhibits they             
          prepared in anticipation of trial.                                          






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