Emmanuel M. and Blessing N. Nwankwo - Page 18

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               Mr. Nwankwo’s records with respect to his travel expenses do           
          not satisfy the requirements of section 274(d) and the                      
          regulations thereunder.  Petitioner testified at trial that he              
          did not keep a log book or any travel records for 2002 and that,            
          in fact, he did not begin keeping a log book for his travel                 
          expenses until very recently.  Although Mr. Nwankwo testified               
          that he no longer had receipts from 2002, he also stated that               
          many of his travel expenses were charged to his personal credit             
          card.  However, petitioners provided no credit card statements              
          (that could have easily been reproduced by contacting their                 
          credit card company) as evidence.  We are therefore unpersuaded             
          that Mr. Nwankwo incurred the costs he purports in taxable year             
          2002 and, accordingly, sustain respondent with respect to this              
          issue.                                                                      
               With respect to the employee benefit programs expenses, the            
          record is devoid of any evidence showing that petitioners                   
          incurred such costs.  Accordingly, we must sustain respondent               
          with respect to this issue.                                                 
               With respect to the disallowed deductions for repair and               
          maintenance expenses, Mr. Nwankwo testified at trial that he                
          presented “a bag of receipts” to the agent during the examination           
          of their 2002 return, but that the agent refused to look at them.           
          Petitioners did not recall the dollar amount or number of the               
          receipts contained in the bag, they did not reproduce these                 






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