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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.
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