Mila Alemasov and Victor Popov - Page 10




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          each of the categories of expenses.  In addition to petitioner’s            
          testimony, petitioners provided a host of credit card statements            
          to purportedly substantiate the claimed expenses.  Notations were           
          made beside some of the charges, and petitioners, in preparation            
          for trial, categorized some of the expenses on spreadsheets                 
          attached to the credit card statements.  In particular, the Court           
          considers the expenses claimed by petitioners as follows.                   
          Advertising Expenses                                                        
               With respect to the advertising expenses of $376,                      
          petitioners’ spreadsheet reflects payments of cash in March,                
          June, July, and September of 2002 for advertisements in Russian             
          papers directed to real estate investors.  Aside from the                   
          spreadsheet, no evidence, such as copies of the advertisements,             
          was offered to support the claimed deduction for advertising.               
          Petitioners’ evidence does not satisfy the Court that those                 
          expenses were incurred.  Accordingly, the Court sustains                    
          respondent’s determination disallowing the claimed advertising              
          expenses.                                                                   
          Car and Truck Expenses                                                      
               Petitioners claimed car and truck expenses of $4,991.  To              
          substantiate these expenses, petitioners provided a spreadsheet             
          detailing the date, location, and amount of each expense, along             
          with a very brief description of the nature of the expense.  For            
          almost every car and truck expense that petitioners claimed to              







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Last modified: November 10, 2007