J.J. Zand - Page 52

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          none of them had independent knowledge pertaining to his                    
          underlying claimed expenses for travel and entertainment.                   
               By the Court's Order dated October 9, 1992, summaries of the           
          diaries for 1973 (Pet. Exh. 3114), 1974 (Pet. Exh. 3116), 1975              
          (Pet Exh. 3118), 1976 (Pet. Exh. 3119), 1977 (Pet. Exh. 3120),              
          1978 (Pet. Exh. 3195), and 1979 (Pet. Exhs. 3202 and 3206), were            
          not received in evidence.  Additionally, because there were no              
          diaries for 1980 and 1981, the Court did not receive in evidence            
          petitioner's summaries (Exhs. 3209, 3211, and 3214) of travel and           
          entertainment expenses claimed for those years.                             
               Petitioner's diaries do not meet the "adequate records"                
          substantiation requirements necessary to deduct travel and                  
          entertainment expenses pursuant to section 274.                             
                                         1973                                         
               Although petitioner claimed a deduction of $98,481.64 on his           
          1973 tax return for travel and entertainment expenses, only                 
          $80,192.81 was recorded in CTC's disbursements journal.                     
          Petitioner claimed cash expenses of $17,500, but his travel diary           
          showed no more than $8,154 in cash expenses.  Some of these were            
          for personal rather than business expenses.  His return preparer            
          estimated petitioner's cash expenses by comparing the number of             
          checks petitioner wrote for cash with the number of days his                
          diary shows he was out of the United States.  No allowance was              
          made for any personal travel.  Hence, petitioner is not entitled            





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