Kelvin & Arlene Jackson - Page 22




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               2. Internet Design Expenses                                            
               Petitioners presented at trial invoices for Web site design            
          from Nigel Gusdorf of $320 and $1,160, paid April 25 and                    
          September 28, 2001, respectively.  On Schedule C of their 2001              
          joint Form 1040, petitioners claimed and respondent allowed a               
          deduction of $2,900 for “WEBSITE”.  Petitioners failed to show              
          that the $1,480 in invoices they presented was not included in              
          their previously allowed deduction.  Accordingly, the Court                 
          concludes that petitioners are not entitled to an additional                
          Schedule C deduction on their 2001 tax return for Web site design           
          expenses.                                                                   
               3. Travel Expenses                                                     
               As stated supra, the strict substantiation requirements of             
          section 274(d) apply to travel expenses.  Petitioners presented             
          invoices from Northwest Airlines and Doubletree Hotel in the                
          amounts of $221.50 and $458.84, respectively, for a trip to                 
          Columbia, South Carolina, from November 24 to 28, 2001.                     
          Petitioners produced at trial a document, which was previously              
          given to respondent, entitled “Business Use of Car Tax Year 2001”           
          that provided “11/24 to 11/28/01 Columbia, S.C. Conducted                   
          Workshop at Black owned bookstore--agreement w/bookstore to carry           
          books.  Airline & Hotel documentation provided.”  However, Mrs.             
          Jackson did not produce the agreement she entered into with the             
          bookstore.                                                                  







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