-7- 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011