- 14 - 1173 (D.C. Cir. 1990), and Brown v. Commissioner, T.C. Memo. 1989-89, affd. without published opinion 916 F.2d 710 (4th Cir. 1990). These cases are distinguishable. Unlike the taxpayers in Matthews, petitioners have taken a position that is untenable and have failed to establish that they made full disclosure of their position to respondent. Unlike Brown, this is not a case where respondent failed to act over a period of years when fully informed of the facts. We sustain respondent’s determination on this issue. Crestmark’s Claimed Business Deductions Respondent disallowed Crestmark’s claimed business expenses on the grounds that it had failed to establish that these were ordinary and necessary business expenses and that they were expended for the purpose designated. With respect to the meals and entertainment expenses, respondent also determined that Crestmark failed to meet the substantiation requirements of section 274. On brief, Crestmark concedes that the meals and entertainment deductions have not been substantiated. We conclude that Crestmark has also failed to establish the validity of its other claimed deductions. Section 162 generally allows a deduction for all the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or business. The determination of whether an expenditure satisfies thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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