- 120 - 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.Page: Previous 110 111 112 113 114 115 116 117 118 119 120 121 122 123 124 125 126 127 128 129 Next
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