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journal for 1979 does not list any disbursements from CTC to CDC
as payment of management fees.
Thus, petitioner presented no evidence that the management
fees for 1978 and 1979 were paid; likewise, there is no evidence
of specific offsets made in payment of the management fees for
which the deductions were claimed. Therefore, these claimed
management fees for 1978 and 1979 are not deductible by
petitioner because they are not his ordinary and necessary
business expenses; furthermore, the amounts claimed were not
shown to have been paid.
G. Claimed Deductions for Consulting Fees or Salary
CDC issued two invoices to CTC, dated February 29, 1980, in
the amount of $6,487.83, and April 9, 1980, in the amount of
$461.73. These invoices were offered in support of deductions
claimed for consulting fees and salaries of $102,101 and for
investment counsel fees of $4,500. Petitioner's cash
disbursements journal for 1980 does not reflect payment of these
amounts. Therefore, petitioner is not entitled to deductions
claimed for consulting fees and salaries of $102,101 and
investment counsel fees of $4,500 for 1980 because these amounts
are not his ordinary and necessary business expenses and the
amounts were not paid.
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