Edward and Ruth Kelly - Page 8

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                  During the years at issue Shearson Lehman had a policy of                               
            reimbursing employee travel and entertainment expenses, subject                               
            to certain documentation and other requirements.  Mr. Kelly                                   
            received reimbursements from his employer, and claimed deductions                             
            for unreimbursed entertainment expenses, in the amounts set forth                             
            below:                                                                                        
            Amount Deducted for                                                                           
            Year          Amount Reimbursed        Unreimbursed Expenses                                  
            1986             $4,415.00                    $25,200                                         
            1987              3,965.00                     125,299                                        
            1989              5,611.81                      22,480                                        
            1990              2,397.70                     212,440                                        
            1991              6,562.81                      21,400                                        
            1992              6,426.42                      22,385                                        
                  1As reduced by 2 percent of adjusted gross income.                                      
                  2As reduced by 20 percent.                                                              
            Petitioners have no documents in their possession supporting the                              
            claimed unreimbursed entertainment expenses for taxable years                                 
            1986, 1987, 1990, 1991, and 1992.  Mr. Kelly used to have an                                  
            expense diary for 1986, which he produced to respondent's agent                               
            in the course of the audit.  The agent informed Mr. Kelly that                                
            the diary was of no value in substantiating the claimed                                       
            deductions.  Mr. Kelly subsequently lost the diary in the course                              
            of an office move.  Petitioners did introduce in evidence an                                  
            expense diary for 1989 together with receipts.  The diary lists                               
            total expenses of $5,702.41.  There are receipts to confirm                                   
            $5,085.76 of the claimed expenses, and for some claimed expenses                              






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