Haralampos Katerelos and Irene Katerelos - Page 53

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            Pont, 308 U.S. 488, 495-496 (1940).  Ordinarily, an expense is                                
            necessary if it is appropriate and helpful to the operation of                                
            the taxpayer's trade or business.  Commissioner v. Tellier, 383                               
            U.S. 687, 689 (1966); Carbine v. Commissioner, 83 T.C. 356, 363                               
            (1984), affd. 777 F.2d 662 (11th Cir. 1985).                                                  
                  To substantiate their claimed deductions for automobile                                 
            expenses, petitioners rely on the testimony of Mr. Katerelos and                              
            a document he prepared three weeks prior to the trial herein that                             
            purports to reconstruct in very summary fashion the business use                              
            of his automobile (summary).  We are unwilling to rely on the                                 
            testimony of Mr. Katerelos or on the document he prepared in                                  
            anticipation of trial to prove either (1) that petitioners                                    
            actually incurred such expenses or (2) that if such expenses were                             
            incurred, they were ordinary and necessary expenses with respect                              
            to petitioners' business, NDV.                                                                
                  With respect to Mr. Katerelos' testimony regarding the                                  
            automobile expenses at issue, in addition to our having found                                 
            that his testimony is generally not credible, his testimony with                              
            respect to his use of an automobile for NDV's business is in                                  
            conflict with an insurance application he signed in May 1988 for                              
            the Lincoln that he claims he used for business purposes through-                             
            out 1987 and during 1988 until he purchased a 1987 Cadillac.  In                              
            that application, the box marked "no" was checked in response to                              
            a question as to whether the Lincoln was used for business                                    





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