- 20 - appeared, at least on paper, as not directly involved. It is difficult to tell from the settlement the nature of the $5,500 portion of the monthly payments. At the very least and in essence, petitioner had the right to earn income in connection with the bingo operation, and he was successful in protecting that right from the interference of the Lichtys and perhaps others. The $5,500 monthly payments were not in exchange for an equity interest but instead were a cost of continuing the bingo business operation. Accordingly, we hold that November is entitled to deduct the $5,500 portion of the payments made to the Lichtys through their corporate entity for the years under consideration. Has Petitioner Shown That $10,350, $35,436, and $35,436 Were Incurred for Supplies for the 1991, 1992, and 1993 Tax Years, Respectively? Respondent disallowed the above-listed amounts due to petitioner’s failure to substantiate that the amounts were expended for deductible business supplies. Petitioner did not offer any evidence at trial regarding these amounts. Accordingly, respondent’s determination on these items is sustained.Page: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
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