Keith F. Marason - Page 18

                                        - 18 -                                        
                         Huda Mustapha       396                                      
                         Shelly Jue          2,100                                    
                         Unidentified         94                                      
                         Total               3,518                                    

               For 1989 respondent concedes the $1,355 payment to Joseph              
          Clare, and we deem petitioner to have conceded the $877                     
          miscellaneous amount, which he failed to discuss in either of his           
          briefs.  After concessions only the payments to Shelly Jue, Gina            
          Cagampan, and Patrick Marason remain in dispute for 1989.                   
               Shelly Jue was petitioner's apartment mate.  Petitioner does           
          not discuss what business services she is alleged to have                   
          rendered.  Patrick Marason was petitioner's brother.  Petitioner            
          testified that Patrick has an accounting degree and that he                 
          assisted petitioner with his client files and office work,                  
          including maintenance of a mailing list.  Neither Cagampan, Jue,            
          nor Patrick Marason was called to testify, nor did petitioner               
          furnish them with Forms 1099.  Without objective evidence we are            
          unable to accept petitioner's uncorroborated testimony that they            
          performed services for his business in either 1989 or 1990.                 
               Gina Cagampan, however, had worked with petitioner at the              
          same firm before he left it to join Coopers & Lybrand.  She had             
          worked as a secretary then, and it is reasonable to infer that              
          their relationship remained work related.  Respondent does not              
          dispute that petitioner paid Cagampan $3,110 in 1989.  A                    
          deduction for that amount will therefore be allowed.                        






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