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credible, however, that the checks written to the AAU and the
Western Springs Rec Center were for RBS-related expenses incurred
with basketball school sessions and tournament entry fees that
occurred contemporaneous to their payment. Specifically, and for
purposes of our decision, the record includes checks drafted to
the AAU and the Western Springs Rec Center in the following
amounts:
2000 2001 2002
Checks drafted to:
AAU $642 $2,664 $400
Western Springs
Rec Center 521 380 200
Total 1,163 3,044 600
As to the remainder of the canceled checks, we find
petitioner’s testimony and the receipt provided for Western
Springs Rec Center credible to substantiate only the foregoing
expenses.
The hotel receipts provided correspond to petitioner’s
credible testimony regarding tournaments that RBS entered in
2000, and therefore, we hold that petitioner has satisfied the
heightened substantiation requirements under section 274(d) with
respect only to these expenses--$3,870.04 for taxable year 2000.
As to the remaining items, the American Express statement,
and an itemized cellular phone bill, neither the credit card
statement nor the phone bill rises to the substantiation standard
required. The American Express statement is for an account held
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Last modified: November 10, 2007