Howard L. Burris, Sr. and Barbara J. Burris - Page 12




                                       - 12 -                                         
               4.  Travel, Entertainment, and Meals                                   
               Petitioners deducted travel expenses of $61,601 in 1990,               
          $100,601 in 1991, and $18,638 in 1993.  Petitioners also deducted           
          entertainment and meal expenses of $12,636 in 1990, $25,693 in              
          1991, and $20,294 in 1993.  Petitioner generally testified that             
          he traveled to Europe to meet with various representatives of               
          banks and trusts to secure funding for the Texas high speed train           
          project.  He did not provide any other detail regarding his                 
          travel, entertainment, and meal expenses.  Petitioners’ primary             
          argument is that Price Waterhouse, their tax preparer, would not            
          have listed the deductions unless the deductions were proper,               
          and, therefore, they are entitled to deduct petitioner’s travel,            
          entertainment, and meal expenses.                                           
               Petitioner did not produce documents to support the claimed            
          deductions for travel, entertainment, and meals.  Petitioner                
          provided several theories as to why the documents were                      
          unavailable:  First, petitioner forwarded the documents to                  
          support his deductions to Price Waterhouse.  According to                   
          petitioner, Price Waterhouse, as part of its document retention             
          policy, destroyed the documents.10  Second, petitioner’s                    
          secretary died in the early 1990's, and, therefore, petitioner              


               10   At trial, Michael A. Halpert, a revenue agent for the             
          Internal Revenue Service, testified that Price Waterhouse                   
          provided him with credit card statements and a spreadsheet of               
          travel expenses for tax year 1991.                                          





Page:  Previous  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  21  Next

Last modified: May 25, 2011