Group Administration Premium Services, Inc., et al. - Page 15

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          at issue.  However, the summary is titled “supplies”, and there             
          are no disputed deductions on the supplies issue.                           
               Exhibit 102 is most deficient, however, with respect to the            
          copies of the receipts included therein.  There is no indication            
          of the relationship between the additional expenses and the                 
          corporations' business.  In order to be deductible, a business              
          expense must be an ordinary and necessary expense of doing                  
          business.  Sec. 162(a).  The receipts do not show the ordinary              
          and necessary business purposes of the expenses, but rather                 
          reflect mostly personal items, including groceries and minor                
          office supply items.  Even with the supply items listed, there is           
          no way to determine whether these receipts correspond to the                
          additional deductions claimed.  Exhibit 102 does not carry                  
          petitioners’ burden of substantiating the office expense                    
          deductions.  Therefore, we uphold respondent’s determination on             
          the office expenses.                                                        
               Petitioners claim additional travel and entertainment                  
          expenses for GAPS of $11,119 and for JJM of $3,565.  Petitioners’           
          claim that exhibit 104 supports these deductions.  Respondent               
          objects to the exhibit on the grounds of relevancy, lack of                 
          completeness, hearsay, and lack of trustworthiness.                         
               As with exhibit 102, we find it unnecessary to rule on                 
          respondent’s objection, because the evidence on the claimed                 
          travel and entertainment deductions is similarly deficient.  Even           





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