There
will be some relief from the paperwork as you may be able to use some of
the records you are already producing. The absolute worst omission
is to completely ignore the rules and not make any attempt.
The following is a Tax Court Memorandum that explains the authority of
the Executive Branch and Judicial Branch over you. If you want to
control your own destiny, then I can assist you and you can look at the
suggestions in the "Solutions
Section" of this page.
Bishop v. Commissioner, T.C. Memo. 2001-82
|
|
| UNITED
STATES TAX COURT |
| |
| RANDALL AND LYNN BISHOP, Petitioners v.
COMMISSIONER OF INTERNAL |
| REVENUE, Respondent |
| |
| Docket No. 14129-98.
Filed
April 4, 2001. |
| |
| |
| P husband (H) carried on a financial planning
business on behalf of |
| individual clients. R disallowed various deductions claimed by H
during |
| 1994 on Schedule C filed with Ps' 1994 return and also
determined that Ps |
| were subject to the sec. 6662, I.R.C., accuracy-related penalty. |
| |
| 1. Held: R's disallowance of various Schedule
C deductions is sustained |
| in substantial part. |
| |
| 2. Held, further, no portion of R's deduction
disallowance may be |
| treated as a disallowance of Schedule A itemized deductions
rather than of |
| Schedule C deductions. |
| |
| 3. Held, further, R's penalty against Ps for
the whole of petitioners' |
| underpayment of tax for the taxable year is sustained under sec.
6662, |
| I.R.C. |
| |
| |
| Michael G. Moore, for petitioners. |
| |
| Nancy L. Spitz, for respondent. |
| |
| |
| MEMORANDUM OPINION |
| |
| HALPERN, Judge: By notice of deficiency dated
May 13, 1998 (the |
| notice), respondent determined a deficiency in petitioners'
Federal income |
| tax for 1994 in the amount of $58,632 and an accuracy-related
penalty in |
| the amount of $11,726.40. Petitioners have conceded certain of |
| respondent's adjustments giving rise to that deficiency. The
issues |
| remaining for decision are (1) certain adjustments by respondent
to |
| deductions claimed by petitioners for depreciation, office
expenses, |
| rental expenses, and expenses for meals and entertainment, (2)
certain |
| ancillary consequences of respondent's adjustments, and (3)
petitioners' |
| liability for the accuracy-related penalty. <<ENDNOTE
1>> |
| |
| Some facts have been stipulated and are so
found. The stipulation of |
| facts, with accompanying exhibits, is incorporated herein by
this |
| reference. We need find few facts in addition to those
stipulated and |
| shall not, therefore, separately set forth our findings of fact.
We shall |
| make additional findings of fact as we proceed. Petitioners bear
the |
| burden of proof. See Rule 142(a). |
| |
| Unless otherwise indicated, all section
references are to the Internal |
| Revenue Code in effect for the year at issue, and all Rule
references are |
| to the Tax Court Rules of Practice and Procedure. |
| |
| |
| BACKGROUND |
| |
| Hereinafter, petitioners Randall and Lynn
Bishop will be referred to as |
| the Bishops or, individually, as Randall and Lynn. |
| |
| At the time of the petition, the Bishops
resided in Bonita Springs, |
| Florida. |
| |
| During 1994, the Bishops resided in
Burlingame, California. Until July |
| 8, 1994, Randall was employed as a financial planner by Wells
Fargo Bank |
| in San Francisco, California, and, during 1994, Lynn was
employed as a |
| flight attendant. During 1994, Randall also carried on a
financial |
| planning business (the financial planning business) separate
from his |
| employment by Wells Fargo Bank. Customers of the financial
planning |
| business came from referrals to Randall or from seminars
conducted by |
| Randall. The Bishops made a joint return of income for
1994, filing a |
| U.S. Individual Income Tax Return, Form 1040 (the Form 1040),
which |
| included, among other schedules, a Schedule A, Itemized
Deductions (the |
| Schedule A), and a Schedule C, Profit or Loss From Business
(Sole |
| Proprietorship) (the Schedule C). Petitioners reported the
results of the |
| financial planning business on the Schedule C. Petitioners
computed the |
| taxable income of the financial planning business under the cash
receipts |
| and disbursements method of accounting. The Schedule C reports
gross |
| receipts of $424,497 and net profit of $203,020. |
| |
| In part, respondent's determination of a
deficiency in tax results from |
| the following adjustments (disallowances) of deductions claimed
on the |
| Schedule C: |
| |
| Depreciation
$34,726 |
| Meals & entertainment 40,000 |
| Office expenses
24,091 |
| Rental expenses
18,247 |
| Travel
17,584 |
| Seminars
15,260 |
| Presentations
12,675 |
| |
| |
| On brief, petitioners concede the following:
(1) the correctness of |
| respondent's disallowance of any deduction for travel, (2) the
correctness |
| of a portion of respondent's disallowance of a deduction for
depreciation, |
| (3) the correctness of a portion of respondent's disallowance of
a |
| deduction for office expenses, (4) that the amounts claimed for
"seminars" |
| and "presentations" are amounts paid for meals and
entertainment, which |
| are subject to the 50-percent disallowance rule of section
274(n), and (5) |
| the correctness of a portion of respondent's disallowance of a
deduction |
| for meals and entertainment (including the amounts claimed for
"seminars" |
| and "presentations"). |
| |
| We accept all of petitioners' concessions.
After concessions, the |
| deductions still in issue are as follows: |
| |
| Depreciation
$13,232 |
| Office expenses
8,762 |
| Rental expenses
23,170 |
| Meals and entertainment
8,719 |
| |
| |
| DISCUSSION |
| |
| I. DEDUCTIONS |
| |
| A. Introduction |
| |
| We must determine petitioners' entitlement to
the deductions still in |
| issue for depreciation, office expenses, rental expenses, and
meals and |
| entertainment. Because petitioners' principal challenge is
substantiating |
| their entitlement to those deductions, we first set forth the
pertinent |
| parts of section 274(d), which sets forth requirements for
substantiating |
| certain deductions: |
| |
| SEC. 274(d)
Substantiation Required.--No deduction or credit shall |
| be allowed-- |
| |
| (1)
under section 162 or 212 for any traveling expense |
| (including
meals and lodging while away from home), |
| |
| (2)
for any item with respect to an activity which is of a |
| type
generally considered to constitute entertainment, |
| amusement,
or recreation, or with respect to a facility used in |
| connection
with such an activity, |
| |
| *
* * |
| |
| (4)
with respect to any listed property (as defined in |
| section
280F(d)(4)), |
| |
| unless the taxpayer substantiates
by adequate records or by |
| sufficient evidence corroborating
the taxpayer's own statement (A) |
| the amount of such expense or
other item, (B) the time and place of |
| the travel, entertainment,
amusement, recreation, or use of the |
| facility or property, or the date
and description of the gift, (C) |
| the business purpose of the
expense or other item, and (D) the |
| business relationship to the
taxpayer of persons entertained, using |
| the facility or property, or
receiving the gift. * * * |
| |
| Section 280F(d)(4) includes, among the
definitions of "listed |
| property", "any computer or peripheral
equipment". |
| |
| At the conclusion of the trial in this case,
the Court, recognizing |
| that substantiation was petitioners' principal challenge,
ordered the |
| parties to develop a form of schedule, to be filled in by
petitioners, |
| which would set forth each item still in issue, with appropriate |
| references to evidence in the record for each element necessary
to sustain |
| a deduction. The parties have complied with that order, and the
Court |
| relies on that schedule (petitioners' substantiation schedule)
for |
| direction to evidence in support of petitioners' claims. |
| |
| |
| B. Depreciation |
| |
| The depreciation deductions here in question
are, in actuality, |
| deductions under section 179, which allows certain taxpayers to
treat as |
| an expense that is not chargeable to capital account the cost of
certain |
| depreciable property. The deduction under section 179 is allowed
for the |
| taxable year in which the depreciable property is placed in
service. The |
| property here in question consists of a computer, certain
elements of |
| computer memory for that computer and for other computers, and a
flatbed |
| computer scanner (the computer equipment) described by
petitioners on a |
| Form 4562, Depreciation and Amortization (Including Information
on Listed |
| Property), appurtenant to the Schedule C. The computer equipment
is listed |
| property, within the meaning of section 274(d)(4). See, e.g.,
Dugan v. |
| Commissioner, T.C. Memo. 1996-155. <<ENDNOTE 2>>
Therefore, petitioners |
| must satisfy the substantiation requirements of section 274(d).
The |
| elements to be proved with respect to listed property are set
forth in |
| sec. 1.274-5T(b)(6), Temporary Income Tax Regs., 50 Fed. Reg.
46016 (Nov. |
| 6, 1985). Those elements include the amount of
"business/investment" use |
| based on an allocation of the time the computer equipment is
used. |
| Petitioners have failed to offer either adequate records or any
evidence |
| substantiating Randall's own statements with respect to such
use. See sec. |
| 1.274-5T(c), Temporary Income Tax Regs., 50 Fed. Reg. 46016
(Nov. 6, |
| 1985). Petitioners have, therefore, failed to satisfy section
274(d) and, |
| as a result, may claim no deduction under section 179 for the
computer |
| equipment. See Dugan v. Commissioner, supra ("Given that
petitioner has |
| failed to demonstrate the business purpose for the computer
expense in |
| accordance with section 274(d), the [section 179] deduction is |
| disallowed."). |
| |
| |
| C. Office Expenses |
| |
| Petitioners claim a deduction for office
expenses in the amount of |
| $8,762. |
| |
| Section 162(a) allows as a deduction "all
the ordinary and necessary |
| expenses paid or incurred during the taxable year in carrying on
any trade |
| or business". Office expenses of the type claimed by
petitioner, e.g., |
| postage, if paid or incurred during the taxable year in carrying
on any |
| trade or business, can qualify as deductible section 162(a)
expenses. See |
| sec. 1.162-1(a), Income Tax Regs. The
adequate-records-or-sufficient- |
| corroborating-evidence standard of section 274(d) is not
specifically |
| applicable to such expenses. Nevertheless, a taxpayer is
required by |
| section 6001 to keep records and to substantiate the amounts
giving rise |
| to claimed deductions, and, if he does not, respondent cannot be |
| considered arbitrary or unreasonable in denying the deductions.
Roberts v. |
| Commissioner, 62 T.C. 834, 836-837 (1974); Cook v. Commissioner,
T.C. |
| Memo. 1991-590 (citing Hradesky v. Commissioner, 65 T.C. 87, 90
(1975), |
| affd. per curiam 540 F.2d 821 (5th Cir. 1976)); see sec.
1.6001-1(a), |
| Income Tax Regs. |
| |
| Randall did not keep a regular set of books
reflecting the income and |
| expenses associated with his financial planning business. To
substantiate |
| the office expenses and meals and entertainment here in issue,
petitioners |
| refer us to (1) various entries in a diary, Randall's
"daily planner", (2) |
| his NationsBank VISA card summary statement for 1994, and (3)
various |
| receipts relating to meals and entertainment expenses and office
expenses. |
| We must decide whether and to what extent that evidence is
adequate to |
| substantiate the business expense deductions that remain in
issue. |
| |
| With respect to the items of office expense
set out on petitioners' |
| substantiation schedule, with four exceptions, petitioners'
evidence fails |
| to satisfy one or more of the elements necessary to establish |
| deductibility as ordinary and necessary business expenses under
section |
| 162. For example, a number of items are listed in Randall's
daily planner, |
| indicating a business purpose, but do not appear in the
NationsBank VISA |
| card summary or relate to one of the receipts in evidence. In
other words, |
| there is no proof of payment. For other items, there is proof of
payment, |
| but the items are not listed in the daily planner resulting in a
failure |
| to establish a relationship to Randall's business. |
| |
| Based on petitioners' substantiation schedule,
we find that petitioners |
| are entitled to a deduction for office expenses in the sum of
$2,429.05. |
| |
| |
| D. Rental Expenses |
| |
| Section 162(a)(3) allows a deduction for
rentals paid for the use of |
| property in a trade or business. |
| |
| On the Schedule C, petitioners claimed a
deduction for rentals in the |
| amount of $18,247. In the petition, they assigned error to
respondent's |
| disallowance of that amount. On brief, petitioners claim a
deduction for |
| rentals in the amount of $23,170. Petitioners have not moved to
amend the |
| petition to assert an overpayment in tax. Nonetheless, since
respondent |
| has not objected to the increased claim for a rental deduction
on the |
| ground that petitioners failed to plead an overpayment, we
assume that |
| such overpayment issue was tried by consent of the parties. See
Rule |
| 41(b)(1). In any event, we allow no deduction for rental
payments. The |
| rental expense in question is claimed by petitioners to
represent the |
| rental costs of rooms in which Randall held financial planning
seminars to |
| educate and attract new clients. |
| |
| Petitioners' substantiation schedule directs
us to entries in Randall's |
| daily planner as substantiation for the entire $23,170 of
alleged rental |
| expense. Randall testified that he conducted seminars as a way
of |
| attracting new clients. Typically, the daily planner entry
includes a |
| dollar amount allegedly representing the cost of renting the
room in which |
| the seminar was held. Petitioners have furnished no evidence
that any of |
| those alleged rental costs were in fact incurred: No canceled
checks, no |
| receipts, no inclusion in the NationsBank VISA card summary. We
find that, |
| having offered no evidence of actual payment, petitioners have
failed to |
| sustain their burden of establishing that they are entitled to a
rental |
| expense deduction. See Hyde v. Commissioner, T.C. Memo. 1992-419
("This |
| Court is not bound to accept the unverified, undocumented
testimony of |
| petitioner"), affd. without published opinion 9 F.3d 112
(7th Cir. 1993). |
| By not offering independent evidence that the seminars even took
place |
| (e.g., brochures, attendance lists, or the testimony of one or
more |
| attendees), petitioners have failed even to furnish a basis for
the Court |
| to estimate, under the authority of Cohan v. Commissioner, 39
F.2d 540 (2d |
| Cir. 1930), the amount allowable as rental expense. As we stated
in Hyde |
| v. Commissioner, supra: |
| |
| However, in order to make an
estimation, 'there [must] be sufficient |
| evidence to satisfy the trier that
at least the amount allowed in the |
| estimate was in fact spent or
incurred for the stated purpose'. |
| Williams v. United States, 245
F.2d 559, 560 (5th Cir. 1957). Until |
| the trier has that assurance from
the record, relief to the taxpayer |
| would be "unguided
largesse". Id. |
| |
| Petitioners have failed to establish that they
are entitled to any |
| deduction for rental expense. |
| |
| |
| E. Meals and Entertainment |
| |
| Petitioners claim a deduction under section
162(a) for meals and |
| entertainment in the amount of $8,719 ($17,438 before taking
into account |
| the 50-percent reduction in the deductibility of such expenses
provided |
| for by section 274(n)(1)). <<ENDNOTE 3>> |
| |
| The substantiation requirements of section
274(d) apply to |
| entertainment activities. Section 274(a)(1)(A) places additional |
| restrictions on the deduction of expenses with respect to
entertainment |
| activities. Section 1.274-5T, Temporary Income Tax Regs., 50
Fed. Reg. |
| 46014 (Nov. 6, 1985), contains the substantiation requirements
for |
| deductible, business-related entertainment, including meals with
customers |
| or clients. <<ENDNOTE 4>> The applicable
requirements, contained in |
| paragraph (b) of section 1.274-5T, Temporary Income Tax Regs. |
| (substantiation of amount, time, place, business purpose, and
business |
| relationship), are satisfied by the Exhibit B1 and B2 formats. |
| |
| Petitioners' substantiation schedule
separately lists (1) expenditures |
| totaling $13,051.56, for restaurant meals with clients,
potential clients, |
| and persons referring potential clients (restaurant meal
expenses), and |
| (2) expenditures totaling $4,386.66 for meals and entertainment
where, in |
| petitioners' words, "there may have been 'major
distractions not conducive |
| to business discussion', i.e., sporting events, shows,
etc." (other |
| entertainment expenses). |
| |
| For most, but not all, of the restaurant meal
expenses, petitioners |
| have set forth the business purpose of the meal, and they have
attempted |
| to substantiate the claimed business purpose by referring to the |
| appropriate entry in Randall's daily planner. In most, but not
all, cases, |
| the actual expenditure of funds has been substantiated by
reference either |
| or both to Randall's NationsBank VISA card summary for 1994 or
his |
| restaurant receipts for that year. Unless there is (1) a clearly
stated |
| business purpose for a restaurant meal expense, (2) the item is
included |
| in Randall's daily planner, thereby supporting the claimed
business |
| purpose, and (3) the expenditure is verified by the NationsBank
summary or |
| by a restaurant receipt, an essential element of substantiation
is |
| lacking, and we sustain respondent's disallowance of a deduction
for that |
| item. |
| |
| In reviewing petitioners' substantiation
schedule to determine the |
| adequacy of the alleged substantiation, we note that
"business purpose" is |
| often referred to in cryptic terms, e.g., "open",
"close", "partial", |
| "A.L. T.D.A.", "LNL", "RLTY", etc.
In some cases, we have been able to |
| decipher the meaning of the term from Randall's testimony, and,
in some |
| cases, we have not. We are not required to speculate as to the
nature of |
| the business purpose of any expenditure. See Lingham v.
Commissioner, T.C. |
| Memo. 1977-152. The fact that Randall may have been dining with
a client |
| "is not conclusive of the business character of the meals,
for at least |
| some of these people may also have been personal friends of * *
* |
| [Randall]". Sanford v. Commissioner, 50 T.C. 823, 827
(1968), affd. per |
| curiam 412 F.2d 201 (2d Cir. 1969). Therefore, where the
business purpose |
| of a meal with a client is not readily discernable from the
record, we |
| find the expense to be nondeductible. |
| |
| Applying the foregoing criteria to the
restaurant meal expenses, we |
| find that petitioners have provided adequate substantiation of
restaurant |
| meals costing a total of $6,411.28. |
| |
| There are six items set forth as other
entertainment expenses. Of the |
| six items, three are not referred to in Randall's daily planner.
Thus, |
| there is no corroboration of the stated business purpose. Most |
| importantly, for none of the items is there any indication that
some |
| "business discussion or activity" was associated with
the entertainment. |
| See sec. 274(a)(1)(A), (d); and sec. 1.274-5T(b)(3)(iv) and
(b)(4)(iii), |
| Temporary Income Tax Regs., supra. Therefore, we find that
petitioners are |
| entitled to no deduction for any of the other entertainment
expenses. |
| |
| |
| II. SCHEDULE A VERSUS SCHEDULE C DEDUCTION
DISALLOWANCE |
| |
| All of respondent's proposed adjustments
decrease expenses claimed on |
| the Schedule C and, correspondingly, increase petitioners'
adjusted gross |
| income for 1994. Petitioners claim that, based upon
"guidelines set out in |
| audits of prior years", they treated a portion of the
expenses listed on |
| the Schedule C as Schedule A itemized deductions on the premise
that the |
| expenses were associated with Randall's wages from Wells Fargo
Bank rather |
| than with his own financial planning business. In fact, an
attachment to |
| line 46 of the Schedule C lists "other expenses",
totaling $76,180, and |
| reduces the total by $39,084 which, instead, is deducted on line
20 of the |
| Schedule A as unreimbursed employee expenses. Petitioners argue
that, |
| because a portion of the expenses listed on the Schedule C was,
in effect, |
| not taken on the Schedule C but taken, instead, on the Schedule
A, a |
| portion of the disallowance of those deductions should,
likewise, be a |
| disallowance of the itemized deductions reflected on line 20 of
the |
| Schedule A. <<ENDNOTE 5>> Respondent argues that
there is nothing in the |
| record to support petitioners' position and, moreover, there is
no |
| authority that supports such treatment. |
| |
| We agree with respondent. There is no
indication in the record as to |
| which of the "Other Expenses" listed on the attachment
to line 46 of |
| Schedule C actually relate to Randall's wages from Wells Fargo
Bank or |
| which expenses petitioners actually intended to transfer from
the Schedule |
| C to the Schedule A. At a minimum, petitioners must show that
the |
| deductions disallowed by respondent were among the expenses
transferred to |
| the Schedule A, which they have not done. We, therefore, reject |
| petitioners' request to treat any portion of respondent's
deduction |
| disallowance sustained herein as a reduction of petitioners'
itemized |
| deductions on the Schedule A. |
| |
| |
| III. ACCURACY-RELATED PENALTY |
| |
| Section 6662 provides for an accuracy-related
penalty (the accuracy- |
| related penalty) in the amount of 20 percent of the portion of
any |
| underpayment attributable to, among other things, negligence or |
| intentional disregard of rules or regulations (without
distinction, |
| negligence), any substantial understatement of income tax, or
any |
| substantial valuation misstatement. Respondent determined the
accuracy- |
| related penalty against petitioner. Although the notice states
that |
| respondent bases his imposition of the section 6662(a)
accuracy-related |
| penalty upon "one or more" of the three grounds listed
in section |
| 6662(b)(1)-(3), the issue presented by this case and our
resolution |
| thereof demonstrates that the only possible ground for
imposition of the |
| penalty is section 6662(b)(1), which imposes a penalty in the
amount of 20 |
| percent of the portion of the underpayment that is attributable
to |
| "negligence or disregard of rules or regulations".
Negligence has been |
| defined as lack of due care or failure to do what a reasonable
and prudent |
| person would do under like circumstances. See, e.g., Hofstetter
v. |
| Commissioner, 98 T.C. 695, 704 (1992). Section 6664(c)(1)
provides that |
| the accuracy-related penalty shall not be imposed with respect
to any |
| portion of an underpayment if it is shown that the taxpayer
acted in good |
| faith and that there was reasonable cause for the underpayment.
The |
| determination of whether a taxpayer acted in good faith and with |
| reasonable cause is made on a case-by-case basis, taking into
account all |
| pertinent facts and circumstances. "Circumstances that may
indicate |
| reasonable cause and good faith include an honest
misunderstanding of * * |
| * law that is reasonable in light of all of the facts and
circumstances, |
| including the experience, knowledge, and education of the
taxpayer." Sec. |
| 1.6664-4(b)(1), Income Tax Regs. |
| |
| Petitioners acknowledge their failure to keep
adequate records in |
| support of their claimed deductions for expenditures subject to
the |
| substantiation requirements of section 274(d), e.g., travel and |
| entertainment expenses (including meals with clients), and they
concede |
| that the accuracy-related penalty applies to any underpayment
attributable |
| to deduction disallowances with respect to such expenditures.
They argue, |
| however, that they made "a good-faith attempt to maintain
proper |
| documentation in accordance with applicable rules and
regulations" as |
| regards the other section 162 expenses, and that the penalty
should not |
| apply to any underpayment attributable to the disallowance of
deductions |
| attributable to those expenses. |
| |
| We note that petitioners have conceded all or
a portion of every |
| deduction challenged by respondent, not merely the deductions
subject to |
| section 274(d). Moreover, we have found that petitioners'
records fail to |
| sustain a large portion of the deductions remaining in issue.
Under those |
| circumstances, we sustain the negligence penalty for the whole
of |
| petitioners' underpayment of tax. |
| |
| To reflect the foregoing, |
| |
| Decision
will be entered |
| under
Rule 155. |
| |
| <<ENDNOTES>> |
| |
| 1/ The deficiencies also reflect adjustments
to petitioners' itemized |
| deductions, personal exemptions, the credit for self-employment
taxes, and |
| the sec. 164(f) deduction for one-half of self-employment taxes,
all of |
| which derive from the principal adjustment and are not directly
disputed |
| by petitioners. |
| |
| 2/ Petitioners offered no evidence that the
computer equipment is |
| excepted from the definition of listed property because it was
used |
| exclusively at a regular business establishment owned or leased
by |
| Randall, which, with certain exceptions not here relevant, is
not, also, a |
| dwelling unit. See sec. 280F(d)(4)(B). Indeed, confirmation
documents with |
| respect to the purchase of the computer equipment show that it
was shipped |
| to the address appearing on the Form 1040, which we assume to be |
| petitioners' residence. |
| |
| 3/ The allegedly deductible expenditures are
contained in Exhibits B1 |
| and B2 accompanying petitioners' reply brief. |
| |
| 4/ Mistakenly, petitioners cite sec.
1.274-2(f)(2)(i), Income Tax |
| Regs., which provides a quiet-business-meals exception but which
applies |
| to "[b]usiness meals and similar expenditures paid or
incurred before |
| January 1, 1987". |
| |
| 5/ Although petitioners do not indicate the
tax benefit to be derived |
| from their requested reattribution of a portion of respondent's
proposed |
| deduction disallowances, we surmise that one such benefit is the
resulting |
| reduction in the loss of petitioners' itemized deductions under
sec. |
| 68(a)(1) and (b), which, for 1994, equals 3 percent of
petitioners' |
| adjusted gross income in excess of $111,800. By restoring
deductions to |
| Schedule C, petitioners reduce adjusted gross income and,
thereby, reduce |
| their loss of itemized deductions under sec. 68(a)(1) and (b).
There is |
| also an increase in petitioners' total miscellaneous itemized
deductions |
| in excess of 2 percent of adjusted gross income due to the
reduction in |
| that number. |
Here
is a list of documents you already prepare in your business that are
useful in proving the elements of the business activities or use
of the equipment (think of the "5 w's" in relationship to the
required information 1. What/Amount 2. When/Time-Date 3. Where/Place 4.
Why/Business Purpose and Benefit Expected 5. Who/Business Relationship
of People and/or business):
You
can use a tape recorder to record other information and transcribe the
tape(s) at a later time.
- Help To Keep Your Life In Balance
