Lee B. Arberg and Melissa A. Quinn - Page 42




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          travel, meals and entertainment, and computer expenses, such                
          evidence necessarily falls short of meeting the heightened                  
          substantiation requisites of section 274.  The dearth of relevant           
          testimony compounds these shortcomings, and the disallowed or               
          questionable nature of the alleged underlying businesses raises             
          yet another barrier.                                                        
               In addition, with respect to the $42,570 claimed as other              
          interest, certain further rules come into play.  The record                 
          establishes that $42,569.95 was incurred as margin interest on              
          the E Trade account.  However, because the Court has concluded              
          that activity in the E Trade account must be attributed to                  
          Ms. Quinn, and because no claim or showing has been made that               
          Ms. Quinn conducted a securities trading business, the                      
          limitations of section 163(d) with respect to investment interest           
          would be applicable.  Moreover, since petitioners have offered no           
          substantiation concerning any offsetting investment income, the             
          Court is not in a position to evaluate petitioners’ situation               
          within the strictures of section 163(d) and thereby to conclude             
          that any amount would be allowable for deduction in 2000 or                 
          available for carryover in future years.                                    
               To summarize, petitioners are not entitled to claimed                  
          expenses except as allowed by respondent as miscellaneous                   
          deductions on Schedule A.                                                   








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