George H. and Evelyn G. Cooper - Page 7

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            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                             







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