Kai-Chung C. and Meekhing T. Lam - Page 7

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               For other categories of expenses, including insurance,                 
          interest, depreciation, legal and professional, car and truck,              
          travel, and meals and entertainment expenses, petitioner offered            
          no testimony and submitted no documentation.                                
               B.   1996 Rental Income                                                
               Petitioner did not present any documentation or offer any              
          testimony regarding the $3,424 of additional rental income                  
          respondent determined petitioner earned in 1996.                            
          II. Audit and Deficiency Notice                                             
               Respondent began examining petitioners’ returns for the                
          years at issue in October 1997.  Respondent repeatedly asked                
          petitioners to submit documentation to support each of the items            
          they claimed on the returns.  Petitioners failed to submit                  
          documentation that would substantiate many of their expenses.               
               Respondent issued a deficiency notice in which he made                 
          adjustments to the Schedule C expenses petitioners claimed,                 
          increased petitioners’ income by the amounts of rental payments             
          they failed to include, and determined that petitioners are                 
          liable for the accuracy-related penalty.  Respondent disallowed             
          the Schedule C expenses on the grounds that they were not                   
          ordinary and necessary business expenses, lacked sufficient                 
          substantiation, or were personal in nature.                                 
               Petitioners timely filed a petition.                                   







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