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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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