Gunasundran R. Pillay and Kalaivani Govender - Page 10

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               With respect to advertising and supplies expenses,                     
          petitioner has not established the business purpose of these                
          expenditures or that they were WTS’s expenses, as opposed to                
          personal expenses or the corporation’s expenses.  The same is               
          true for utilities expense.  For example, petitioner introduced a           
          number of invoices from AT&T Wireless.  The invoices are                    
          addressed to petitioner, however, and do not reference WTS.  In             
          addition, some of the invoices list petitioners’ home address,              
          while others list the office in Sacramento that WTS shared with             
          the corporation.  Petitioner did not introduce evidence linking             
          the telephone number listed on the invoice to WTS, such as a WTS            
          business card or WTS letterhead.  Nor did petitioner provide                
          evidence of his personal utilities expense or the corporation’s             
          utilities expense, which may have been circumstantial evidence              
          that WTS used the AT&T Wireless service and incurred the expense            
          in question.                                                                
               WTS paid one-half of the rent for the office space it shared           
          with the corporation.  While rent generally is an ordinary                  
          business expense, petitioner testified that the office space was            
          “only a professional front” for WTS; i.e., WTS used it solely to            
          meet clients.  Given the limited use that WTS made of the office            
          space, as well as the dearth of clients in the years at issue, it           
          appears that this expenditure may not have been a necessary                 
          expense.  See Alondra Indus., Ltd. v. Commissioner, T.C. Memo.              






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