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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 Club
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