9
GACC. Petitioner did not maintain a business bank account,
despite having deducted service charges as a business expense for
both years at issue. He also admitted at trial that he failed to
keep organized records or receipts of expenses, and failed to
provide receipts supporting the majority of expenses claimed on
his returns.
Although petitioner appears to have some experience in the
area of brokerage, he conceded that he has not sold one piece of
property or business enterprise in all of his years engaged in
this activity, with the exception of the sales of one-third of
his interest in KRBA to Mr. Leonard, and, later, his remaining
interest in KRBA to third parties. Petitioner did not present
documentation of these transactions, and the record fails to
indicate whether his role in the transactions was that of a
broker or simply a seller.
Petitioner testified that he spent 15 to 20 hours per week
on brokerage activity and was regularly contacting potential
sellers and buyers. However, the receipts presented by
petitioner in support of this contention are dated almost
exclusively during the Christmas and Labor Day weekend holidays.
Moreover, the travel was largely to Indianapolis, Indiana, where
his son lives with petitioner's former wife, and several of the
receipts presented in support of his "business" expenses were for
tickets to Sea World and Disneyland.
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