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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originally made were in some manner or another erroneous.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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