Roy W. and Sharon P. Oswandel - Page 5




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          (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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