J.J. Zand - Page 53

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          to a deduction for travel and entertainment expenses for 1973 in            
          excess of the amount allowed by respondent.                                 
                                         1974                                         
               Although petitioner claimed a deduction of $126,068.70 on              
          his 1974 tax return for travel and entertainment expenses, only             
          $76,347.25 was recorded in CTC's disbursements journal.                     
          Petitioner claimed cash expenses of $24,500, but his travel diary           
          showed no more than $7,495 in cash expenses.  Some of these were            
          for personal rather than business expenses.  One of the claimed             
          travel expenses was a check dated November 22, 1974, to Diesel              
          Power for $27,618.39 and reflected on petitioner's workpapers as            
          "Hotel Bill".  Again, the return preparer estimated cash expenses           
          in the same manner as he did for 1973.                                      
               Furthermore, petitioner also claimed a $24,000 deduction for           
          Kitzbuhel office expenses.  There is no evidence to support such            
          claimed expense on Schedule C of his 1974 tax return.                       
               Thus, petitioner is not entitled to a total deduction for              
          1974 travel and entertainment expenses in excess of the amount              
          allowed by respondent.                                                      
                                         1975                                         
               Although petitioner claimed a deduction of $157,946.48 on              
          his 1975 tax return for travel and entertainment expenses, only             
          $108,446.48 was recorded in CTC's disbursements journal.                    
          Included in the total amount that he deducted, petitioner claimed           





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