- 5 - thus not taxable; (3) the deficiency was not a legally enforceable deficiency; and (4) petitioners were denied their Sixth Amendment right to confront and cross-examine respondent’s employees who audited their return. We shall not painstakingly address petitioners’ assertions “with somber reasoning and copious citation of precedent; to do so might suggest that these arguments have some colorable merit.” Crain v. Commissioner, 737 F.2d 1417, 1417 (5th Cir. 1984); Williams v. Commissioner, supra at 139. Accordingly, we sustain respondent’s position that petitioners underreported their income by $14,555 with regard to the landscaping business. Travel and Meals and Entertainment Expenses Petitioners claim that they paid $2,035 for travel expenses and $2,660 for meals and entertainment expenses.3 The travel expenses represent the airfare costs Mr. Knelman incurred flying between his residence in Ohio and his place of business in California, whereas the meals and entertainment expenses represent the cost of meals Mr. Knelman incurred during his trips to California. Respondent disallowed the deductions relating to both expenditures, contending that the travel and the meals and entertainment expenses were nondeductible personal expenses and 3 Their claim to the meals and entertainment deduction equals $1,330 after the 50-percent reduction pursuant to sec. 274(n).Page: Previous 1 2 3 4 5 6 7 8 9 Next
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