- 66 - T.C. 239, 258 (1984), affd. without published opinion 786 F.2d 1174 (9th Cir. 1986); see also Schaefer v. Commissioner, T.C. Memo. 1994-444. Toraya has the burden of establishing that the payments to Motomi served a business purpose and were reasonable in amount. Motomi testified that she maintained an office in her home to count credit card charges, to calculate the hours worked by Toraya's employees for preparing the payroll twice monthly, and, if she had time, to check the waitress tags to make sure they were added correctly. She stated that she recalled receiving money from Toraya to reimburse her for her office expenses, but she could not remember how much she received, when it was paid, or for which expenses she was reimbursed. Nakamura testified that Toraya's board of directors authorized him to reimburse Motomi for the expenses she incurred in establishing an office in her home in San Bruno, California. Nakamura stated that he considered the money paid to Motomi to be nontaxable to the Kudos because it was a reimbursement of her expenses. Both Motomi and Nakamura testified that Toraya had agreed to reimburse Motomi for the expenses she incurred in maintaining an office in her home on Toraya's behalf. There is no evidence that Toraya agreed to compensate Motomi for her time or efforts in performing those activities. Consequently, Toraya must prove that the payments to Motomi reimbursed expenses she incurred on Toraya's behalf and that they were reasonable. The record,Page: Previous 56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 71 72 73 74 75 Next
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