- 21 - 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 forPage: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Next
Last modified: May 25, 2011