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amounts that add up to the $17,380 in cash expenses claimed on
the 1977 tax return. It appears that alleged cash expenses
included on the 1978 through 1981 returns include payments to
petitioner's housekeeper, payments for cablevision, payments to a
CDC employee, American Express and VISA payments, payments to
Ohio State University, payments to the Port Royal Club and the
Columbus Country Club, a number of payments for flowers and
gifts, at least $12,500 in checks to "cash" or "J.J. Zand" and a
$5,000 wire transfer to Austria near the Christmas holidays.
However, no cash expenses claimed for 1978 through 1981 have been
reconciled with petitioner's tax returns for those years, and no
business purpose for any claimed cash expenditures in those years
has been disclosed on the record.
In 1974, 1975, and 1976 petitioner claimed, either
separately or as part of his travel and entertainment, various
expenses attributable to his apartment in Kitzbuhel, Austria. He
and his family used Kitzbuhel personally for Christmas skiing
vacations, and CTC employees considered Kitzbuhel as petitioner's
personal rather than business location.
In 1975 and 1976 petitioner included $10,000 and $5,000 in
expenses for Kitzbuhel as part of his claimed travel and
entertainment expenses. Neither the fact of payment nor the
business purpose for any expense attributable to Kitzbuhel has
been proven. All of the expenses claimed for Kitzbuhel were
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