Joseph B. Campbell - Page 30




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          expenses”, (2) personal date books for 1993 and 1994, and (3)               
          photocopied receipts and correspondence for 1993 and 1994.  The             
          “account of expenses” appears to have been prepared in                      
          preparation for this proceeding, and we give it no weight other             
          than as a summary of items allegedly substantiated by other                 
          documentary evidence.  The personal date books contain                      
          handwritten notes with a few numbers that do not appear to                  
          correlate with the numbers in petitioner’s account of expenses.             
          The receipts and correspondence are incomplete and insufficient             
          to satisfy the requirements of section 162 and, where applicable,           
          section 274.  For example, most of the documents dealing with               
          expenses that seem to be covered by section 274 do not provide              
          the date, amount, place, and essential character of the                     
          expenditure as required by section 1.274-5(c)(2)(iii), Income Tax           
          Regs.                                                                       
               For the reasons described above, we are unable to discern              
          any adequate factual or legal basis for allowing petitioner a               
          deduction for any of the expenses claimed under these                       
          circumstances.  Accordingly, we hold that petitioner has not                
          proven he was entitled to deduct either the meeting payments or             
          his claimed unreimbursed direct expenses as ordinary and                    
          necessary business expenses under section 162(a).                           










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