Barry D. and Suzanne B. Whalley - Page 34

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          News and the Asset Protection Guide.  Petitioner provided                   
          canceled checks for these items.  Petitioner's testimony                    
          establishes that he used these materials either as resources or             
          to stay abreast of trends in the investigation and surveillance             
          industry.  Therefore, petitioner may deduct $665 in 1991 and $181           
          in 1992 for the cost of these items.                                        
               K. Laundry and Linen                                                   
               For 1991 and 1992, petitioner deducted $225 and $233,                  
          respectively, representing the cost of cleaning petitioner's                
          suits and shirts.  This is clearly a personal nondeductible                 
          living expense under section 262.                                           
               L. Outside Services                                                    
               For 1991 and 1992, petitioner deducted $4,100 and $2,920,              
          respectively, for outside services, which respondent disallowed             
          in full.  Petitioner testified that these were amounts paid to 15           
          different informants, or "snitches", to obtain information.                 
          Petitioner paid these amounts in cash; he did not issue Forms               
          1099 to the recipients, nor did he provide any receipts or other            
          documentation to support the deduction for the taxable years in             
          issue.  We find for respondent on this matter.                              
               M. Telephone                                                           
               For 1991 and 1992, petitioner deducted $1,787 and $1,433,              
          respectively, for cellular phone expenses allegedly incurred in             








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