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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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