Consequently, they were unaware of the date the trial was to be held and therefore should be excused from failing to appear for trial. The normal practice of the Magistrate Division of this court is to conduct a case management conference, at which time a trial is scheduled if necessary. Taxpayers testified that they do not remember any case management conference and did not receive notice of the trial. Counsel for the department indicated that he was unaware of whether a case management conference had been conducted. After considering the testimony, and being in doubt as to whether adequate notice was given, the court determined that it would hear this matter on the merits.
Taxpayers appeal from the disallowance of items claimed as business expenses.
IRC 162 and 174 require taxpayers to provide substantiating evidence of the business nature of the expense. Taxpayers knew enough in preparing their own return to know that these types of items are potentially deductible. What taxpayers apparently did not know is that they did not meet the conditions imposed by the code to qualify for these deductions. The court finds the auditor's disallowance of these items was proper. The largest source of disputed expenses was for travel, including meals and lodging.