Sharon T. Myrick - Page 6




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          substantiate some of the expenses claimed on her 2002 Schedule C.           
          These documents included an alleged customer list, a receipt for            
          a purchased laptop computer, a canceled check for prepaid legal             
          services, receipts for supplies totaling $21.38, a canceled check           
          for postage, invoices for the alleged rental of a postage                   
          machine, and phone bills.4                                                  
               Altogether, petitioner’s documentation fell woefully short             
          of demonstrating that she was involved in a trade or business and           
          represented only a fraction of the expenses petitioner attempted            
          to deduct on her return.  Petitioner testified that she had more            
          records when she prepared her 2002 return than the records she              
          provided to respondent or the Court, but that they had been lost            
          or removed from her computer files.  Petitioner also stated that            
          the only business she did in 2002 relating to event planning was            
          a Crab Feast Safety Tour, for which she provided documentation              
          indicating that the tour had been canceled, and that she could              
          not get any more bookings that year.                                        
               Evidence of one canceled event, along with a sampling of               
          receipts, canceled checks, and invoices, is insufficient to show            
          that petitioner was continuously and regularly involved in the              
          trade or business of event planning for the primary purpose of              

               4 Petitioner testified that she kept receipts, but that her            
          son had thrown away many of her receipts by mistake when she                
          replaced some flooring in her house where the records were kept.            
          Petitioner also testified that she kept a notebook in which she             
          recorded expenses, but that she had thrown it away by mistake.              





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