- 30 - One check is a payment to a "Nita Mott" on January 12, 1991, which he testified was paid "to get a special room" in the hotel at Sun Valley to facilitate his surveillance efforts. The other check is for $591 and drawn on Mrs. Whalley's personal account. This check, which is dated November 15, 1991, was supposedly payment for the Sun Valley trip. Petitioner, however, allegedly made that trip nearly 10 months earlier in January of 1991. When petitioner was then asked whether he was testifying that he "went to Sun Valley in January of 1991 and * * * [his] wife paid for that in November of 1991", he responded: "No, the actual trip was in 1992." Petitioner's testimony is dubious regarding this matter. The record likewise fails to substantiate the expenses claimed by petitioner for 1992. Finally, with respect to petitioner's alleged investigatory interviews, they seem to always be connected with expensive meals for which he generally provided few names and vague explanations of business purpose. Furthermore, nothing in the record indicates contemporaneous record keeping. Accordingly, petitioner has failed to meet the requirements of section 274(d), and we, therefore, sustain respondent's determination for the taxable years in issue. G. Business Promotion Expenses For 1991 and 1992, petitioner deducted $2,039 and $165, respectively, for alleged business promotions paid to various individuals and associations for items such as the Rotary ClubPage: Previous 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 Next
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