Pennel Phlander Irwin - Page 5

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            expenses underlying the denied deductions were either personal in                             
            nature, or inadequately substantiated.  On the other hand, in a                               
            2-page document entitled "The Audit of '91", by Pennel P. Irwin,                              
            petitioner states in part:                                                                    
                  Because of the nature of the business, expenses vary                                    
                  depending upon the type of writing being done.  For                                     
                  non-fiction writing, expenses are limited to just those                                 
                  items directly related to the subject being researched.                                 
                  For fiction writing all personal experiences and                                        
                  observations are all business experiences and                                           
                  observations * * * so there is no distinction between                                   
                  personal and business costs * * *.  (Example:  Upon                                     
                  awaking in the morning the toiletry and dressing                                        
                  process carried out by myself, and observed in others,                                  
                  is research whose end observations are included in the                                  
                  fictional writing for similar actions carried on by the                                 
                  various characters; and therefore, different grooming                                   
                  products would be justifiable research expenses as well                                 
                  as different clothing that conveys fit and feel * * *.)                                 
                  Thus all expenses I incur are either for business                                       
                  research or business maintenance or business                                            
                  production, though I have, out of choice, not declared                                  
                  all of these---such as food, clothing, toiletries or                                    
                  amusements.                                                                             
                                                                                                         
            In an attempt to substantiate his claimed deductions, petitioner                              
            provided copies of canceled checks, drawn on his personal                                     
            account.  Petitioner, however, failed to indicate the precise                                 
            nature of the expenses underlying many of the checks.  For                                    
            example, petitioner lists many of the expenses under the broad                                
            rubric, "research materials", without specifying the expenditure                              
            in any detail.                                                                                
                  During the course of the examination of petitioner's return,                            
            respondent sought certain materials, including a log or diary to                              

            amounts of $101 in 1991 and $172 in 1992, attributable to the                                 
            costs of a computer disk drive and a cabinet.                                                 



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