Kelvin & Arlene Jackson - Page 23




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               Petitioners have not presented any evidence substantiating             
          the alleged business purpose of Mrs. Jackson’s trip, other than             
          their document and her uncorroborated testimony at trial, and,              
          therefore, have failed to meet the substantiation requirements of           
          section 274(d).  Furthermore, although petitioners did not claim            
          a deduction for travel expenses on their joint 2001 Form 1040,              
          respondent allowed $2,071 in travel expenses.  Petitioners have             
          not shown that the Northwest Airlines and Doubletree travel                 
          expenses were not included in the expenses previously allowed by            
          respondent.  Accordingly, the Court concludes that petitioners              
          are not entitled to a deduction for travel expenses in excess of            
          the $2,071 previously allowed by respondent.                                
               4. Mail and Post Office Box Expenses                                   
               Petitioners presented at trial an invoice from Bacon’s                 
          Mailing Service $3,858.71 for taxable year 2001, discussed supra.           
          Petitioners did not claim an expense for mailing services on                
          their 2001 joint Form 1040.  Respondent contends that petitioners           
          have not shown that the invoice was paid in 2001 as the                     
          prepayment date was not provided.  The Court agrees with                    
          respondent.  Accordingly, the Court concludes that petitioners              
          are not entitled to a Schedule C deduction for mailing expenses             
          for taxable year 2001.                                                      
               Petitioners claimed a deduction for “PO RENT” of $64 on                
          Schedule C of their joint 2001 Form 1040, which respondent                  







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