- 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 hisPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
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