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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 his
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