- 38 - wires, items 30 and 30(a) and 30(b) were funds paid directly-–wired directly to the client's personal account. As true throughout petitioner's testimony at trial, petitioner offers no explanation for the nature of the services he provided to Ms. Lynch, the problems that arose with respect to those services, or the reason for his payment of those funds. Finally, in one instance, petitioner claims to have made a direct refund of fees to Dr. Strom in the amount of $930. When asked about this payment at trial, petitioner stated as follows: Well, basically, it had to do with--I looked after his investments and as well as doing his personal-–doing his taxes and corporate work, and he didn't feel the investments performed as well as expected. Some of this had to do with indemnities and the value of some of his investments. For the above reasons, we find that petitioner has failed to meet his burden of proving that any of the direct payments offset his gross receipts or can be deducted under section 162. Accordingly, we hereby sustain respondent's determination as to these payments.Page: Previous 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 Next
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