- 221 -
as rent. Other payments identified in the cash disbursements
journal as made to CDC were paid on behalf of Mr. Castoe.
On brief petitioner does not point to any specific amounts
in the record that would substantiate the payments to CDC for
management fees in 1978 and 1979. Instead, he claims that the
payments may have been made by offsetting amounts due him from
CDC. However, petitioner has provided no reconciliations or
other workpapers documenting when and in what amounts any such
offsets were made. Accordingly, the management fees for 1978 and
1979 are disallowed.
For the year 1980 petitioner provided little documentation
in support of expenses claimed for investment counseling in the
amount of $4,500 and consulting and salaries in the amount of
$102,101. He presented only invoices to CTC from CDC dated
February 29, 1980, in the amount of $6,487.83 and April 9, 1980,
in the amount of $461.73. Petitioner's cash disbursements
journal for 1980 does not reflect payment of the amounts claimed.
Therefore, we hold that he has failed to substantiate these
amounts, and they are not deductible.
Page: Previous 211 212 213 214 215 216 217 218 219 220 221 222 223 224 225 226 227 228 229 230 NextLast modified: May 25, 2011