- 9 -
Petitioner has not proven that these items were purchased
and used in his place of business, as opposed to the new home
that he purchased in the same year. Petitioner did not provide
any invoices which might have confirmed that Togar, Inc., sells
oriental rugs and that Lucien Crup sells artwork, and shown a
delivery address or the address of petitioner’s offices. Given
petitioner’s experience as a tax attorney and the amount of the
deduction at issue, we would have expected petitioner to have
such evidence. Petitioner has not proven that he is entitled to
the claimed deduction.13
(III). Language Lessons
The final office expense at issue is a claimed deduction of
$300 in 1993 for language lessons. Petitioner testified that
more than 90 percent of his clients are Asian, and as a result,
he took lessons on Chinese, specifically Cantonese and Mandarin.
To substantiate petitioner's claim, he provided copies of three
checks issued to Fang Huang. Petitioner’s creditablity is
suspect in light of the other explanations he has provided.
Petitioner has not proven that he is entitled to this deduction.
13We note that even if the expenses were substantiated, they
appear to be capital in nature.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011