- 9 -
or telephone number for the Silk Shop either to the examiner or
at trial. The examiner investigated her claim and found that
there had never been a business called the Silk Shop in or around
Coldwater, Michigan, and neither the Chamber of Commerce nor the
County Clerk’s office had any record of a store by that name.
Furthermore, respondent offered evidence at trial from area
telephone books and city directories for the years 1993, 1994,
and 1995; none had a listing for a Silk Shop in or around
Coldwater, Michigan.
The Court finds that Ms. Rhodes at no time purchased items,
either retail or wholesale, from Frank’s, the Silk Shop, or any
other store. Moreover, the Court also finds that Ms. Rhodes did
not purchase items “off the back of a truck” from someone who she
“believed worked for Frank’s”. The Court finds that the
transactions never occurred.
On their Schedules C for Keepsake, petitioners deducted car
and truck expenses of $10,035.16 and $3,772.80 for 1994 and 1995,
respectively. With respect to travel expenses and certain other
expenses, such as expenses relating to the use of listed
properties under section 280F(d)(4)(A), including passenger
automobiles and any other property used as a means of
transportation, section 274(d) imposes stringent substantiation
requirements to document particularly the nature and amount of
such expenses. For such expenses, substantiation of the amounts
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011