Jung K. Yoon and Hee S. Yoon - Page 29

                                       - 29 -                                         
          increased by $22,000 to reflect the advances from suppliers                 
          claimed by petitioners.                                                     
               Petitioners now contend that credit card charges, in                   
          addition to those allowed by respondent, are deductible as                  
          business expenses.  Respondent treated all payments on personal             
          credit cards as personal living expenses.  Petitioners argue that           
          it was unreasonable for respondent to treat the payments in that            
          manner.  Petitioners claim that they are entitled to additional             
          business expense deductions of $17,774.94 on JKY's 1990 return              
          and $26,788.87 on JKY's 1991 return for expenses charged to                 
          personal credit cards.  Petitioners have offered schedules of               
          credit card charges prepared by Caufield that categorize each               
          credit card expenditure.  The underlying credit card statements             
          are not part of the record in this case.  Also, the schedules               
          show that certain statements were not available at the time the             
          schedule was created.  Caufield testified at trial that he                  
          prepared the schedules and consulted Yoon only when Caufield was            
          unclear as to the classification of a charge as business or                 
          personal.                                                                   
               Numerous items claimed as business deductions by petitioners           
          appear to be for travel and entertainment, i.e., restaurant                 
          charges and airline charges.  Petitioners claim that 100 percent            
          of these expenses is deductible, ignoring the 80-percent limit on           
          deductibility under section 274(n).  Furthermore, to prove                  
          entitlement to deductions for travel and entertainment expenses,            




Page:  Previous  15  16  17  18  19  20  21  22  23  24  25  26  27  28  29  30  31  32  33  34  Next

Last modified: May 25, 2011