- 6 - Memo. 1962-132; Gerald D. Roberts Consultants, Inc. v. Commissioner, T.C. Memo. 1991-490, affd. 981 F.2d 1251 (4th Cir. 1992); Houston v. Commissioner, T.C. Memo. 1983-635. Petitioner’s claims to deductions not previously conceded by respondent are based solely on testimony that is not worthy of belief, as set forth below. Inherently Improbable Claims Petitioner claims that every expenditure that he made during 1996 was business related. Justifying his deduction of everything that was charged to his credit card, petitioner testified: “So it’s very difficult for me to distinguish between a personal expense and business expense when it comes to a credit card. I charge most of my business expenses up on a credit card, and I deduct whatever I have paid for that year, I deduct that.” Explaining his deduction of items based on checks payable to cash, he testified: “So personal and business to me are one and the same. It’s no use to pay expenses and maintain two bank accounts.” When cross-examined about an alleged business loan, he stated: “The dental practice and dental lab is one and the same; it is Michael McCann.” Operating under his untenable premise, petitioner deducted payments to his children, ages 11 and 13 during the year in issue, at the rate of his child support obligation, as dental lab contract services expenses. He deducted the cost of hisPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011