- 9 - sought to be deducted. Sec. 1.274-5T(c)(1), Temporary Income Tax Regs., 50 Fed. Reg. 46016 (Nov. 6, 1985). At trial, petitioner presented no documentary evidence to substantiate the claimed expenses. He testified that these expenses related to his employment with Marco’s Auto Body and in the startup of his self-employed activity. Petitioner, however, could not recall what some of the expenses were about. The Court accordingly sustains respondent on this issue. The third issue is respondent’s disallowance of $12,000 in rent claimed as an expense on Schedule C relating to petitioner’s self-employed activity. Petitioner’s auto repair business, Gregorian’s Automotive, was conducted in a separate facility he rented that was located approximately 12 miles away from the location of his employment with Royal Coach, Inc. He testified that he leased the building and paid $1,000 per month for rent. Petitioner presented no documentation, such as canceled checks or receipts to substantiate the $12,000. The Court notes from the evidence that there was some degree of strain between petitioner and Royal Coach, Inc., regarding the private work of petitioner at Royal Coach’s place of business. To relieve that pressure, petitioner rented the separate facility for the purpose of operating his self-employment activity. The Court accepts that testimony but is not prepared to allow petitioner the deductionPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
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