- 10 -
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
Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: November 10, 2007