Emmanuel M. and Blessing N. Nwankwo - Page 22

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          received while driving his 18-wheeler in 2003.  However, he                 
          failed to provide respondent, either at the examination, or                 
          before or at trial, with proof of these expenses.  He did not               
          offer any testimony at trial of these costs.  Accordingly, we               
          must sustain respondent’s determination as to this issue.                   
               With respect to petitioners’ claimed deductions for travel             
          expenses, as previously discussed, section 274(d) imposes                   
          stringent substantiation requirements to document with                      
          particularity the nature and amount of such expenses.  Mr.                  
          Nwankwo testified that these receipts were also kept in the bag             
          that was mistakenly thrown out in the trash by his mother.  Mr.             
          Nwankwo testified that he did not keep a travel log for that                
          year, and the record is devoid of any additional evidence that              
          could prove his travel expenses.  Although Mr. Nwankwo testified            
          that he often used credit cards to pay his travel-related                   
          expenses in 2003, he did not produce any records from his credit            
          card companies to this effect.  Accordingly, we must sustain                
          respondent on 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 repair and maintenance                  
          expenses, Mr. Nwankwo testified that the bulk of the receipts for           






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