Barry D. and Suzanne B. Whalley - Page 30

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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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