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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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Last modified: May 25, 2011