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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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