James B. Miller, Jr. - Page 7

                                        - 7 -                                         
               In 1991, petitioner paid medical expenses relating to his              
          daughters, to employees of his warehouse, and to his own medical            
          needs.                                                                      
               Petitioner often traveled in his automobile to meet with               
          customers and prospective customers.  Petitioner provided                   
          refreshments for customers at his warehouse, and occasionally               
          petitioner purchased lunch for employees, for customers, and for            
          himself during meetings at restaurants.                                     
               On his 1990 and 1991 Federal income tax returns, petitioner            
          claimed deductions for alleged expenses relating to his scrap               
          metal recycling business.  The deductions claimed include alleged           
          miscellaneous expenses relating to petitioner's home office, rent           
          and utilities relating to petitioner's home office and to the               
          warehouse, employee wages, fines and losses from burglaries,                
          legal fees, employee benefits, medical expenses, travel expenses,           
          and meal and entertainment expenses.                                        
               Allegedly due to a loss of many of petitioner’s books and              
          records during the bankruptcy proceeding, the only records                  
          relating to petitioner's scrap metal recycling business that                
          petitioner produced to respondent’s revenue agent during the                
          audit and at trial were:  (1) Copies of the computer spreadsheets           
          reflecting alleged daily and monthly expenses by category for all           
          of 1990 and 1991 except for one month of 1990; and (2) some of              
          the daily cash reports and receipts for 1990 and 1991.                      






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

Last modified: May 25, 2011