Michael Gregorian and Yolanda Gregorian a.k.a. Yolanda Trelles - Page 12

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               Section 274(d)(4) provides generally that no deduction or              
          credit shall be allowed with respect to any listed property                 
          defined in section 280F(d)(4).  Included as listed property under           
          section 280F(d)(4)(A)(i) and (ii) are passenger automobiles or              
          any other property used as a means of transportation.                       
               At trial, petitioner testified that, as a means of                     
          establishing his business, and because of the elite clientele of            
          some of his customers, he or his employees went to the residences           
          or places of business of customers who either had inoperable                
          vehicles or for personal reasons did not care to drive the                  
          vehicles themselves, and petitioner or his employees drove or               
          towed the vehicles to petitioner’s place of business for repairs.           
          After the repairs, the cars were driven by petitioner or his                
          employees and returned to the customer.  As explained by                    
          petitioner, some of his customers were elite individuals in the             
          entertainment industry, and some customers simply refused to                
          drive their vehicle, even if the problem was minor, such as a               
          nonfunctioning headlight.                                                   
               Petitioner maintained no records to document this service.             
          The expenses he incurred in providing this service comes within             
          the record keeping requirements of sections 274(d)(4) and                   
          280F(d)(4)(A)(i) and (ii) referred to above.  The records                   
          necessary to substantiate the amounts claimed should include the            
          dates they were incurred, the times and places they were                    






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Last modified: May 25, 2011