-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'sPage: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
Last modified: May 25, 2011