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The Crabtree Dealerships had a busy year in 1987. Banks
competed to obtain the Crabtree Dealerships' financing business
in 1987. Petitioner maintained close relationships with
representatives of banks and other financial institutions, such
as insurance companies and leasing companies, in order to be sure
that, once a deal was made between the customer and the
dealership, the financing would be approved by a bank or other
financial institution.
Crabtree sold the Crabtree Dealerships around mid-1989, and
Crabtree no longer had access to the Crabtree Dealerships’ books
and records.
During 1987, petitioner resided in Syosset, New York, which
is located in northeastern Nassau County, on Long Island. The
Crabtree Dealerships are about 34 miles from petitioner’s
residence. Driving between Syosset and New Rochelle ordinarily
requires one to pass through Queens and Bronx Counties, and to
cross the East River by one of three toll bridges.
Employee Business Expenses
Business Meals
Petitioner recorded in a diary the amounts he claims he
spent each day for business meals. Each entry in petitioner’s
diary for meals lists the name of the restaurant, the names of
the people present, the type of meal (breakfast, lunch, or
dinner), and the cost of the meal. Petitioner’s diary does not
show the business purpose of any of these meals and does not show
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Last modified: May 25, 2011