Kai-Chung C. and Meekhing T. Lam - Page 12

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          evidence to that effect is petitioner’s own self-serving                    
          testimony, which we do not find to be credible.  Id.                        
               Finally, with respect to the office, bad debt, advertising,            
          and taxes and licenses expenses, petitioner vaguely described               
          what he incurred.  Petitioner did not, however, introduce any               
          documentation to show the amount of any of these expenses.  For             
          the insurance, interest, depreciation, and legal and professional           
          expenses, petitioners offered nothing.                                      
               We conclude that petitioners failed to substantiate any                
          repair and maintenance, supplies, bad debt, office, insurance,              
          interest, depreciation, advertising, taxes and licenses, and                
          legal and professional expenses, and thus they are not entitled             
          to any deduction beyond what respondent previously allowed.  No             
          additional amount may be estimated under the Cohan rule because             
          there is no basis to do so.  See Vanicek v. Commissioner, supra             
          at 742-743.                                                                 
          II. Section 274(d) Expenses                                                 
          We turn next to the business expenses that are subject to the               
          strict substantiation requirements of section 274(d).  In                   
          addition to the general substantiation requirements, taxpayers              
          must substantiate certain business expenses, such as car and                
          truck, travel, and meals and entertainment expenses, by adequate            
          records or by sufficient evidence corroborating the taxpayer’s              
          own statement.  Sec. 274.  The substantiation must show the                 






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