Raymond Strong - Page 19

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          that each recording of an element of expenditure is made at or              
          near the time of the expenditure.  Sec. 1.274-5T(c)(2)(ii),                 
          Temporary Income Tax Regs.  If the taxpayer lacks "adequate                 
          records", then the taxpayer is to provide a written or oral                 
          statement by the taxpayer containing sufficient information in              
          detail as to each element set forth in section 274(d), as well as           
          sufficient other corroborative evidence.  Sec. 1.274-5T(c)(3)(i),           
          Temporary Income Tax Regs.                                                  
               Petitioner’s diary paints a picture of an indefatigable                
          worker (the diary shows that he had business meals on 304 days,             
          even though his tax return showed that he worked only 250 days              
          during 1987) who was, if anything, overly cautious on his tax               
          return (his diary showed the meals cost him $65,777.39, but he              
          deducted only $62,500).  Supra tables 3 and 2.  The bill stubs              
          present an ostensibly plausible backup, in a bewildering variety            
          of styles, sizes, and colors.                                               
               However, neither the diary nor the stubs show (1) the                  
          business purpose of any of the claimed business meals or (2) the            
          business relationship to petitioner of any of the people with               
          whom he dined.  In addition, substantially all the other                    
          information in the record about business meals contradicts the              
          information that is presented in the diary and stubs.  Mercer               
          testified that he, not petitioner, paid for their dinners.                  
          Wright testified that she had many dinners with petitioner during           






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