J.J. Zand - Page 56

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               Some of petitioner's claimed travel and entertainment                  
          expenses were personal.  His workpapers do not show the amounts             
          of the checks for cash that he wrote in 1976.                               
               Consequently, petitioner is not entitled to a deduction for            
          1976 travel and entertainment expenses in excess of the amount              
          allowed by respondent.                                                      
                                         1977                                         
               Although petitioner claimed a deduction of $60,184.24 on his           
          1977 income tax return for travel and entertainment expenses,               
          only $42,631.31 was recorded in CTC's disbursements journal.                
          Petitioner claimed cash expenses of $17,380, but only $6,470 was            
          shown in his travel diary.  At least $4,212.96 was unidentified.            
               Many of the claimed expenses were personal.  Some of the               
          claimed expenses related to meetings with Bill McCabe concerning            
          various Florida real estate projects and exploration of business            
          opportunities in Naples, Florida.                                           
               Petitioner has not shown which travel and entertainment                
          expenses for 1977 were personal and which were business related.            
          Therefore, he is not entitled to the claimed deduction for that             
          year.                                                                       
                                         1978                                         
               Petitioner claimed deductions in 1978 for travel and                   
          entertainment of $74,970, cash expenses of $20,000, and car                 
          expenses of $1,537.03.  Respondent disallowed all of the                    





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