-5-
(Atkinson). Petitioners never gave Atkinson any books or records
to substantiate petitioners’ claimed deductions for petitioner’s
ministerial activities, tuition, mileage, student loan interest,
personal property tax, or noncash charitable contributions.
When the trial of this case was resumed and concluded on
September 11, 2006, petitioners introduced (and the Court
admitted) into evidence 262 pages of documents to substantiate
their claimed deductions. The documents included:
(1) Petitioner’s American Express credit card statement listing
purchases of airline tickets, train tickets, and lodging in
various cities in the amount of $1,857 (attached to the credit
card statement is a handwritten breakdown of estimated mileage
driven in connection with petitioner’s part-time jobs,
ministerial activities, and job searching); (2) an insurance
policy statement listing five cars covered under the policy; (3)
a Colorado vehicle registration/tax ownership receipt listing the
purchase date, purchase price, and taxable value of a car; (4) a
car payment history for a vehicle that petitioner has marked as
sold in February 2000; (5) handwritten notes listing petitioner’s
various destinations for his ministerial activities; and (6) an
account payment statement from Sallie Mae for student loan
payments from 2002 to 2005. Petitioners rely upon the credit
card statement and the handwritten destination list as
substantiation for some of the deductions claimed for
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