- 5 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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