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Kelly might not have been bringing in enough business to warrant
being reimbursed for additional expenses.
Any explanation why some of the expenses were not reimbursed
would be pure speculation, as petitioner's counsel chose not to
elicit any testimony from Mr. Kelly regarding his failure to
request and obtain reimbursement of his entertainment expenses
from his employer.
Petitioner has offered no evidence to show that the
deductions in issue were grossly erroneous. There has been no
showing that the deductions were "phony" or otherwise grossly
erroneous for purposes of the innocent spouse requirement.
Purcell v. Commissioner, supra.
For the foregoing reasons,
An order will be issued
denying petitioner's Motion
for Reconsideration.
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Last modified: May 25, 2011