J.J. Zand - Page 166

                                        - 241 -                                       

               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                 





Page:  Previous  231  232  233  234  235  236  237  238  239  240  241  242  243  244  245  246  247  248  249  250  Next

Last modified: May 25, 2011