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