Gerard and Audrey Kathleen Hennessey - Page 46




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          “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          originally made were in some manner or another erroneous.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 as                   







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