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The only years for which petitioner specifically testified
as to receipts, invoices, or underlying documents relating to
claimed expenses were 1977, 1978, and 1979. However, for the
years 1978 and 1979, as well as 1980 and 1981, his exhibits
containing checks, receipts, or other underlying documents were
not received in evidence. Furthermore, his testimony with
respect to his travel in those years can best be described as
vague with respect to both business purpose and the business
relationship of the persons with whom he allegedly met. It
appears that his testimony confirms that the majority of his
travel in those years related to the business of Diesel Power,
IGOS, CDC and its various subsidiaries and partnerships, real
estate development projects in Florida (Homestead Development and
Southern Florida Real Estate), the exploration of new business
opportunities, startup expenses related to new ventures, and the
sale and subsequent arbitration and litigation with Mr.
Khalatbari regarding his Diesel Power stock. Moreover, while
receipts, invoices and other documents for 1977 are in evidence,
they establish no more than the fact of payment; these documents
do not establish the elements necessary to corroborate
petitioner's testimony for purposes of substantiating his
entitlement to the deductions under section 274.
As part of his travel and entertainment expenses, petitioner
claimed cash expenses that are not reflected as part of travel
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