- 11 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11
Last modified: May 25, 2011