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disorganized set of invoices, receipts, canceled checks, and
other documents from 2001 and 2002. At trial, petitioner offered
almost no testimony explaining the transactions underlying the
deductions on his 2001 and 2002 income tax returns. In his
testimony, petitioner also admitted that he had mistakenly
presented several documents, receipts, and canceled checks that
relate to purely personal expenditures.
Petitioner has failed to carry his burden of proof with
regard to the deductions subject to the limitations of section
274. Petitioner has not presented adequate records which
substantiate the required elements for those expenditures subject
to section 274. Nor has petitioner provided sufficient evidence
to corroborate his statements regarding his deductible
expenditures in 2001 and 2002. We therefore uphold respondent’s
determination that petitioner has not adequately substantiated
his claimed deductions for expenditures relating to travel, meals
and entertainment, or business use of cars or trucks for 2001 and
2002.
As to petitioner’s business deductions not subject to the
limitations of section 274, petitioner also has failed to
adequately substantiate nearly all of the business deductions
claimed on his Schedules C for 2001 and 2002. Petitioner has
presented almost no evidence that links the expenditures
reflected in the receipts, invoices, and checks to his business
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