Mila Alemasov and Victor Popov - Page 11




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          have paid in cash, they did not provide receipts or any type of             
          documentary evidence to support the payment.7  With regard to the           
          other claimed car and truck expenses, petitioners provided a                
          small number of receipts.  Most of the documentation to support             
          these expenses consisted of monthly credit card statements or               
          annual gas card statements.                                                 
               Petitioners presented no records to substantiate that the              
          car and truck expenses claimed on their Schedule C for 2002 were            
          related to the real estate activity or were other than personal             
          expenses.  Although statements from Chevron and Shell reflected             
          the total amounts charged on credit cards during 2002, there is             
          no documentation or other evidence to show that the charges were            
          for ordinary and necessary expenses related to the claimed                  
          business rather than for personal use.  Similarly, other receipts           
          and monthly credit card statements show that money was paid to              
          Union 76 and Geary Automotive Service; however, petitioners                 
          likewise failed to establish that these were ordinary and                   
          necessary expenses of the real estate activity.  For these                  
          reasons, respondent’s determination disallowing petitioners’                
          Schedule C car and truck expenses is sustained.                             





               7The claimed expenses for which no receipts were provided              
          include those for gasoline, repairs, and licenses.                          






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