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the amount was a capital expense of CDC; it was neither an
ordinary and necessary business expense nor an interest expense
of petitioner.
R. Claimed Moving Expense Deduction
In 1979 petitioner deducted a moving expense paid for Mr.
Dutton in the amount of $1,227. Mr. Dutton was an employee of
CDC. Therefore, it is disallowed because it was not an ordinary
and necessary business expense of petitioner.
S. Investment Tax Credits
In the notices of deficiency respondent allowed additional
investment tax credits in the amounts of $280.60 for 1974,
$1,353.53 for 1975, and $695.15 for 1977. Respondent disallowed
investment tax credits in the amounts of $475.89 for 1976,
$688.24 for 1978, and $599.60 for 1979. Respondent determined
that petitioner is liable for investment tax credit recapture of
$344.58 for 1973. Petitioner presented no evidence with respect
to the investment tax credits set forth in the notices of
deficiency. Therefore, he is not entitled to those investment
tax credits disallowed by respondent, and he is liable for the
investment tax credit recapture.
T. Claimed Deductions for Travel and Entertainment Expenses
For the years 1973 through 1981 petitioner's claimed,
allowed, and disallowed travel and entertainment expenses were as
follows:
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