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M. Moving Expense and Investment Tax Credits
As to these two issues, our findings of fact are
dispositive. The claimed moving expense deduction for 1979 was
for Mr. Dutton, an employee of CDC. It was not petitioner's
ordinary and necessary business expense. The investment tax
credits for 1976, 1978, and 1979 were disallowed by respondent,
and petitioner presented no evidence with respect to them.
Therefore, respondent's determinations are sustained.
N. Travel and Entertainment Expenses
A major area of deductions for which payment is disputed is
travel and entertainment. Petitioner claimed enormous and
inflated expenses for travel and entertainment, as shown in our
findings of fact, for the years 1973 through 1981. Respondent
allowed sizable amounts for the years 1973 through 1976, and also
disallowed substantial amounts for those years. All amounts
claimed for the years 1977 through 1981 were disallowed by
respondent.
For the travel and entertainment expenses, not only is the
fact of actual payment in question, but also whether claimed
expenses were ordinary and necessary, whether they were incurred
by petitioner as a sole proprietor, or whether they were the
expenses of Diesel Power or, for later years in issue, a myriad
of other corporate entities with which petitioner was involved.
Also at issue is whether the substantiation requirements of
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