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We sustain in full the deductions claimed by petitioner for
1990 and 1991 for employee wage expenses, including the wage
expenses of the warehouse foreman.
With regard to claimed fines and losses of $2,147 for 1990
and $1,188 for 1991 that are still in dispute, petitioner admits
that some portion of the claimed fines and losses includes
nondeductible traffic fines. Petitioners offer no basis on which
we can make an allocation between allowable and nonallowable
fines and losses. We sustain respondent's disallowance of these
items.
The $8,988 for 1990 and $3,459 for 1991 in disputed legal
fees represent either clearly personal expenses or the business
nature thereof is not adequately established in the record. At
trial, petitioner conceded that $2,500 to $3,500 of these claimed
legal expenses represent personal expense, and petitioner did not
adequately document the nature of the remaining claimed legal
expenses. We sustain respondent's disallowance of the legal fees
still in dispute.
With regard to the $906 in claimed employee benefit expenses
for 1990 and the $774 in claimed medical expenses for 1991 that
are still in dispute, petitioner has failed to substantiate the
nature of these expenses. Petitioner admitted at trial that some
of these claimed expenses were incurred for personal medical care
of two of his daughters. We sustain respondent's disallowance of
the claimed employee benefit and medical expenses.
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