Barry and Penny Knelman - Page 5




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          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).                                                                       





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