Edwin A. Helwig - Page 17

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          notes to the accountant for $1,000 evidenced the worthlessness of            
          the notes, that sale did not occur until December 21, 1993, at               
          the conclusion of K&H’s 1993 year and, hence, petitioner’s 1993              
          tax year.  In addition, petitioner’s sale of his capital or                  
          equity interest in Snacks has not been shown to have had any                 
          particular effect on the worthlessness of the notes.                         
          Accordingly, we find that petitioner has not substantiated his               
          claim for partial worthlessness of the notes during the years in             
               Two remaining issues were addressed by the parties on                   
          brief.6  The first involved $60,143 of Snacks’ operating expenses            
          that were paid and claimed by K&H for its taxable year ended                 
          April 27, 1991.  Respondent determined in the notice of                      
          deficiency that the expenses “are not deductible because * * *               
          [they] were incurred on behalf of * * * [Snacks] and therefore               
          are not trade or business expenses of K&H”.  On brief, respondent            
          maintained the position that the expenses were not K&H’s trade or            
          business expenses.                                                           
               Generally, one taxpayer may not deduct expenses paid on                 
          behalf of another taxpayer.  See, e.g., Dietrick v. Commissioner,            
          881 F.2d 336, 339 (6th Cir. 1989), affg. T.C. Memo. 1988-180.  We            

               6  To the extent that either party did not address an issue             
          raised by the pleadings, we assume that the issue has either been            
          agreed to by the parties or is being abandoned by the party with             
          the burden of proof.                                                         

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