J.J. Zand - Page 144

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          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.                                       














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