- 7 -
petitioner, states that petitioner incurred $25,748 in expenses
during the 1987 tax year, yet the amounts set forth on the
documents total only $17,921.96.
Finally, a summary prepared by petitioner for purposes of
the trial of this case (and about which petitioner testified that
it was a "probable chronology" of his business travel during the
1987 tax year), reports that petitioner incurred business
expenses totaling $27,536 during the 1987 tax year.
When asked which of these amounts was accurate, petitioner
stated that "the actual expenses that I incurred is none of
these. These are different treatments of information at the time
that I was asked to provide information." If petitioner is
unable to accurately determine the amount of his expenses for the
1987 tax year, he cannot expect the Court to do so from the
jumble of data he has submitted.
Petitioner has also failed to show that the claimed expenses
were ordinary and necessary for the conduct of business. Indeed,
petitioner testified that, with the exception of meals (unless
client or staff related), he was reimbursed by Con Tex, Inc., for
all expenses that "legitimately" contributed to its business.
Lastly, petitioner has not met the strict requirements of
section 274(d) as to his claimed travel, entertainment, and meals
expenses. Petitioner provided no evidence as to how much of his
Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011