-14-
connection with his travels to Nevada. For the years in issue,
the record contains documentary evidence of petitioner's travel
and meal expenses; i.e., airline tickets and travel schedules,
and hotel, restaurant, rental car, and credit card receipts.
With respect to petitioner's interviews, he characterized
the amounts he paid to the prostitutes as business related
depending upon whether information gleaned from the interviews
was used in his books. Petitioner has personal credit card
receipts for 1994 supporting the expenditures he incurred to
interview prostitutes away from the brothels. Petitioner does
not have receipts of his cash expenditures in 1993 for the
interviews that took place at the brothels. Nor does petitioner
have records supporting his deductions for advertising, commis-
sions and fees, office expenses, supplies, utilities, or those
expenses comprising "other expenses" for 1994 (with the exception
of the interviews).
Around the time of the parties' preparation of a stipulation
of facts, petitioner prepared a five-page reconstruction of his
expenditures, using information reflected on airline tickets and
itineraries, hotel and rental car bills, credit card receipts,
and petitioner's own memory. This included summary statements
for 1993 and 1994, a flight log, and a log of his interviews.
In the notice of deficiency, respondent disallowed under
sections 162 and 183 all of the expenses claimed on petitioner's
Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 NextLast modified: May 25, 2011