- 2 -
and miscellaneous expenses on Schedule A, Itemized Deductions;
and (2) whether petitioner is liable for the addition to tax
pursuant to section 6651(a)(1) for failure to timely file his
return.
Some of the facts have been stipulated and are so found.
The stipulation of facts, the supplemental stipulation of facts,
and the attached exhibits are incorporated herein by this
reference. At the time his petition was filed, petitioner
resided in Honolulu, Hawaii.
During 1993, petitioner was employed as a car salesman with
South Seas Jeep Eagle (the dealership) in Hawaii. He reported
$65,267 as compensation from the dealership for 1993. In order
to secure customers and make a sale, petitioner would purchase
beverages, food, gifts, and gasoline for them. Petitioner’s
employer did not reimburse him for any expenses incurred.
Petitioner maintained a calendar in which he recorded the amounts
he spent on customers. In the calendar, which is rather
unorganized and confusing, petitioner listed the name of the
customer and the vehicle sold. Petitioner recorded whether he
purchased a snack or meal for the customer and the amounts spent.
Petitioner also recorded when he gave demo rides. Some days have
numbers listed instead of customer names, while other days show
that petitioner had a customer and numerous expenditures were
made.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011