- 43 - As we understand it, petitioner claims that the second payment that he received from Dr. Strom in the amount of $26,700 consisted of an annual fee of $6,500 and the reimbursement of three payments that petitioner allegedly made on behalf of Dr. Strom in the aggregate amount of $21,679.75 (viz, $2,679.75, $12,000, and $7,000). One problem we have with petitioners's testimony is that the total of the fees and reimbursements is $28,179.75, or $1,479.75 more than Dr. Strom's check of $26,700. Another problem we have with petitioner's testimony is that he does not explain why, in preparing the check for Dr. Strom's signature, to reimburse himself for payments made on Dr. Strom's behalf, petitioner included the $7,000 payment to the Employment Development Department that would be due on December 31, 1990, several days later. We do not understand why petitioner did not simply prepare a check for this upcoming payment directly from Dr. Strom to the Employment Development Department. Petitioner contends that the payments made on Dr. Strom's behalf in 1990 are deductible because petitioner received reimbursement for those payments from Dr. Strom, and petitioner included the reimbursements in computing gross income for that year. Petitioner states in his posttrial brief that he included fees of $28,560, fromPage: Previous 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 Next
Last modified: May 25, 2011