- 46 - “general ledgers” suggest that petitioners improperly deducted: (1) Personal items as business expenses; (2) actual travel expenses in addition to per diem amounts; and (3) mortgage payments, automobile payments, and home furnishings as “job travel” expenses. Furthermore, the “general ledgers” were continually revised during the examination of petitioners’ returns. This suggests that petitioners did not keep these records contemporaneously with their expenditures or that entries originally made were in some manner or another erroneous. Respondent properly requested supporting documentation for entries made in the “general ledgers”, but some requests were ignored and many responses were delayed. A taxpayer’s poorly detailed and noncontemporaneous records are hardly proper substantiation for challenged deductions, and secondary sources, such as petitioners’ “general ledgers”, offered in support of a taxpayer’s business expense deductions need not be accepted by respondent or this Court. See Krieger v. Commissioner, T.C. Memo. 1993-347, affd. without published opinion 64 F.3d 657 (4th Cir. 1995); Bard v. Commissioner, T.C. Memo. 1990-431; Farguson v. Commissioner, T.C. Memo. 1983-615. Under the circumstances, including the confusion no doubt caused by the use of similar acronyms for different entities, we find no fault with respondent’s refusal to accept the “general ledgers” and other information provided by petitioners asPage: Previous 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 NextLast modified: November 10, 2007