- 5 -
thus not taxable; (3) the deficiency was not a legally
enforceable deficiency; and (4) petitioners were denied their
Sixth Amendment right to confront and cross-examine respondent’s
employees who audited their return. We shall not painstakingly
address petitioners’ assertions “with somber reasoning and
copious citation of precedent; to do so might suggest that these
arguments have some colorable merit.” Crain v. Commissioner, 737
F.2d 1417, 1417 (5th Cir. 1984); Williams v. Commissioner, supra
at 139. Accordingly, we sustain respondent’s position that
petitioners underreported their income by $14,555 with regard to
the landscaping business.
Travel and Meals and Entertainment Expenses
Petitioners claim that they paid $2,035 for travel expenses
and $2,660 for meals and entertainment expenses.3 The travel
expenses represent the airfare costs Mr. Knelman incurred flying
between his residence in Ohio and his place of business in
California, whereas the meals and entertainment expenses
represent the cost of meals Mr. Knelman incurred during his trips
to California. Respondent disallowed the deductions relating to
both expenditures, contending that the travel and the meals and
entertainment expenses were nondeductible personal expenses and
3 Their claim to the meals and entertainment deduction
equals $1,330 after the 50-percent reduction pursuant to sec.
274(n).
Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011