Daniel R. Blodgett - Page 6




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          the loss of such records, but he has not offered any                        
          reconstruction of his expenditures.                                         
               There is no evidence in the record to substantiate                     
          adequately the section 162(a) expenses in excess of those                   
          conceded by respondent.  In addition, we believe that petitioner            
          did make some business trips during the years in issue, but there           
          is insufficient evidence to determine the facts required by                 
          section 274(d).  Thus, petitioner is not entitled to deduct such            
          expenses, and, pursuant to Lone Manor Farms, Inc. v.                        
          Commissioner, 61 T.C. 436, 440 (1974) (stating that the Court may           
          compute “the correct tax liability for a year not in issue when             
          such a computation is necessary to a determination of the correct           
          tax liability for a year that has been placed in issue”), the               
          carryovers from 1992 and 1993 shall be computed accordingly.                
          III.  Employee Business Expense Deductions                                  
               On Forms 2106, Employee Business Expenses, of his 1994,                
          1995, and 1996 returns, petitioner claimed employee business                
          expenses of $20,103, $56,137, and $24,903. We conclude that the             
          record contains evidence sufficient to substantiate section                 
          162(a) deductions of $3,804, $33,419, and $6,056, relating to the           
          respective years in issue, but not the deductions governed by               
          section 274(d) (i.e., travel, meal, entertainment, and gift                 
          expenses).                                                                  








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