David and Gail Vigil - Page 17




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               Petitioners’ testimony with respect to the supplies expenses           
          was vague.  Mr. Vigil testified that the supplies consisted of              
          computers, envelopes, paper, and stamps for preparing and sending           
          ministry newsletters.  Mrs. Vigil’s testimony described her                 
          purchase of video equipment and tapes for preparing, editing, and           
          duplicating video tapes for Mr. Vigil’s ministry.  She claimed              
          that she bought such equipment in 2001 but also testified that              
          she could not remember honestly.  This testimony is insufficient            
          to satisfy the strict substantiation requirement of section                 
          274(d) applicable to computers as listed property, and it is                
          inadequate either to reconstruct petitioners’ records in support            
          of their $7,862 claimed deduction for supplies or to establish a            
          rational basis upon which the Court can estimate the amount of              
          the deductible expense.                                                     
               We conclude that petitioners have not satisfied the strict             
          substantiation requirements of section 274(d) to support their              
          claimed deductions for car and truck expenses, travel expenses,             
          or meals and entertainment expenses.  Nor have they reconstructed           
          their records or provided evidence sufficient for the Court to              
          estimate the amount of expenses for supplies.  Accordingly,                 
          respondent’s determination that these expenses are not allowable            
          is sustained.                                                               










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