- 19 - Petitioners substantiated a large part of the expenses during their meetings with respondent's Appeals officer by providing the requisite documentation at that time. (3). Interest Expense Deduction (PCCL) The notice of deficiency to PCCL adjusted a claimed interest expense deduction in the amount of $37,777. Respondent disallowed the interest expense deduction because "it has not been established that any amount constitutes an ordinary and necessary business expense or was expended for the purpose designated nor that a bona fide debt existed". For the reasons stated in the "Other Deductions" analysis, respondent had a basis in fact at the time of the notice of deficiency for his position of disallowing the interest deduction. PCCL did not substantiate this claimed deduction until it provided the requisite documents to respondent's Appeals Office subsequent to the filing of the petition. In addition, during the course of respondent's examination, respondent had interviewed a former employee of PCCL with regard to this matter. Respondent was provided with pertinent information that a related entity, Dorrial, Inc., was set up as a "shell corporation", with the purpose of diverting PCCL funds. Also, Paige had provided respondent with information regarding the loan and related company in issue.Page: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
Last modified: May 25, 2011