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(Nov. 6, 1985). Listed property includes passenger automobiles.
Sec. 280F(d)(4)(A)(i).
Petitioner testified that some of the expenses in issue
related to travel, meals, and lodging. Petitioner presented some
credit card receipts and other miscellaneous and disorganized
records in an attempt to substantiate the Schedule C deductions
in issue. Petitioner failed to establish that the claimed rental
and interest expenses were ordinary and necessary business
expenses paid or incurred during 2001 in carrying on a trade or
business. With respect to travel expenses, petitioner did not
satisfy the substantiation provisions of section 274(d).
Respondent’s determination is sustained in this regard.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
Decision will be entered for
respondent.
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