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ordinary and necessary expense of his business. Rather, it
appears that petitioner was purchasing a product. In any event,
petitioner did not substantiate any amount of expenditure greater
than the amounts claimed on the return and not disallowed in the
notice of deficiency. Therefore, petitioner is not entitled to a
deduction for these purchases.2
On the basis on the foregoing,
Decision will be entered
for respondent.
2 The record contains a document that shows that petitioner
paid $29 to Strategic on Dec. 30, 1996, for “Annual Renewal”.
Petitioner stated that this was for renewal of the
distributorship. This amount is de minimis and will not affect
the tax computation, even if not originally claimed.
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Last modified: May 25, 2011