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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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Last modified: March 27, 2008