Timothy Klusken - Page 7




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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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