- 16 - 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.Page: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 NextLast modified: March 27, 2008