- 14 - The parties settled the McMahon Litigation in 1988, and in October of 1989, petitioner destroyed most of the underlying documentation for its expenses from 1971 to 1984 or 1985. Petitioner's management considered them old and irrelevant. But it kept the checks for Sale By Owner and Far Western, reasoning that those expenses were "more current". Petitioner also kept its unaudited books of original entry, and other books based on them. Since 1976, the first contested loss year, a member of the Byrne family has kept the books of original entry. An accountant compiled some of the other ledgers and journals using the information the Byrnes gave him. While prior years' events generate petitioner's claimed net operating losses, including depreciation and interest, the events of 1989 and 1990 generate petitioner's other claimed deductions. Respondent conceded some of these current deductions, and of the amounts remaining in controversy, respondent has admitted that petitioner has substantiated the following amounts: Category 1989 1990 Management fees of Byrne......... $500.00 $3,656.30 Fees/expenses of Charles Byrne III... 276.72 500.00 Repairs............................... 123.14 299.57 Insurance for Automobile.................. 795.80 661.60 on Byrne's Life................. 1,114.10 -0- Telephone.............................. 905.39 1,864.15 Travel................................ 48.77 -0- Dues and subscriptions Newspapers....................... 40.00 92.60 SF Commercial Club............... 75.17 65.00 Office expensesPage: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
Last modified: May 25, 2011