- 34 -
II. Business Expenses
A. Preliminary
On its fiscal 1990 tax return, petitioner claimed business
expense deductions of $689,658. In the notice of deficiency
respondent disallowed only the following business expense
deduction items: Rents--$96,000 out of $101,517 claimed, and
Car/Truck--all of the $29,877 claimed. Respondent did not
disturb the remaining $563,781 of claimed deductions. At trial,
respondent conceded an additional $10,000 of the claimed rent
expenses, leaving $86,000 in disputed rent expenses.
The parties stipulated monthly summaries of a credit card
account in Steve’s name, a copy of a “purported lease between
petitioner and its officers, Steve * * * and Andy * * * ”, and a
deposition Steve gave in a suit by Andy against petitioner and
Steve. Also, Steve provided some testimony on the subject.
At the end of the trial, the Court directed the parties to
file simultaneous briefs and took the trouble to explain to Steve
the purpose of posttrial briefs, in particular the purpose and
detailed format of requests for findings of fact and statements
as to where in the record is the support for each proposed
finding of fact. See Rule 151.11
11Rule 151 provides, in pertinent part, as follows:
RULE 151. BRIEFS
(continued...)
Page: Previous 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 NextLast modified: May 25, 2011