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included on the returns without the benefit of supporting records
or documentation. Rather, in support of the Kitzbuhel expenses,
petitioner relies on telephone calls and meetings ascribed to
Kitzbuhel in his diaries. While the diaries reflect telephone
calls and meetings at Kitzbuhel, they also reflect visits by
family members and the fact that petitioner went to Kitzbuhel to
rest. His 1974 diary shows that petitioner was in Kitzbuhel for
55 days, 9 of which were for rest, and that his daughters,
housekeeper, and girlfriend were in Kitzbuhel for 42 days.
In 1975 petitioner also claimed travel and entertainment
expenses for a London apartment in the amount of $15,000. The
return preparer did not question petitioner or see any underlying
documentation regarding this claim. He simply took petitioner's
word for the $15,000 expense. The workpapers for 1975 show that
$5,000 of the total expenses claimed for the London apartment was
for a car and chauffeur. However, no documentation underlying
the $15,000 in expenses claimed for the London apartment has been
provided. Furthermore, the amount claimed is contrary to
petitioner's testimony that he paid Mr. Khalatbari a flat sum of
$10,000 for the use of his London apartment, including the maid,
car and chauffeur.
Finally, petitioner claims that part of the total travel and
entertainment expenses claimed in 1974 is a $27,618.39 payment to
Diesel Power that was allegedly paid to reimburse it for payment
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