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at different times in various businesses. This is not sufficient
justification for deducting a management fee.
In 1979 the alleged management fee was increased to 15
percent. A similar method of keeping track of the services
rendered by the employees was utilized. Additionally, in
computing the deduction claimed for 1979 petitioner failed to
offset the management fee claimed by the rent credit, a total
amount of $16,269. Petitioner also failed to report the rental
income on his 1979 income tax return.
As substantiation for payment of the management fee claimed,
petitioner again offered workpapers. Although the first page of
these workpapers lists two accounts payable to CDC in the amounts
of $44,475.29 and $7,198.69, petitioner failed to prove that the
alleged management fees claimed in 1978 and 1979 in the amounts
of $72,609 and $67,943 were actually paid. His cash
disbursements journal for 1978 does reflect a number of payments
to CDC. However, the purpose of most of these payments is not
identified, and none of the payments match the amounts reflected
in the summary workpapers. Furthermore, no checks were issued by
petitioner to CDC for management fees. Certain other payments
recorded in petitioner's 1978 disbursements journal are listed
under a column identified as rent. These payments pertain to the
deduction of $31,842 claimed on petitioner's Schedule C for 1978
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