Douglas L. and Nancy H. Maxfield - Page 8

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          and did an estate out there when my cousin died.”  He went to               
          Florida as a “process server and served my ex son-in-law some               
          papers”.  He helped “several old folks” in Texas with Social                
          Security and “got them food stamps and a little money and their             
          medical services.”  He helped another person get veteran’s                  
          benefits.  Petitioner is not licensed to practice law.                      
          Furthermore, he has no records concerning these activities, and             
          there is no indication of what, if any, income petitioner derived           
          from these endeavors.  Second, with regard to the construction              
          activity, petitioner testified that he had closed that activity             
          before the year 2000.  While there is some indication that some             
          work was done on his in-laws’ residence, petitioner’s role in               
          that work is unspecified.                                                   
               Most of the deductions claimed for expenses are patently               
          without legal bases.3  Petitioner claimed deductions for boat               
          expenses, but he has no records to support any business use of              
          the boat.  He has no logs or any other documentation showing the            
          business use of any automobiles that satisfy the requirements of            
          section 274(d).4  Moreover, he deducted both actual expenses and            


               3  The provisions of sec. 7491(a)(1) do not apply.                     
          Petitioners have not satisfied the record-keeping requirements of           
          sec. 7491(a)(2).                                                            
               4  Respondent, however, did allow a deduction for automobile           
          expenses based on mileage that includes an element of the cost of           
          insurance.                                                                  





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