Michael A. McCann - Page 8




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          During the year in issue, petitioner was involved in other legal            
          proceedings of a personal nature, for which there is no record of           
          any expense.  The logical inference from the record is that the             
          payments to Morse were personal expenses inappropriately deducted           
          by petitioner.                                                              
               With respect to a deduction that was claimed for interest on           
          an alleged business loan, petitioner’s tax return preparer, Wayne           
          Paul (Paul), testified that he introduced petitioner to the                 
          lender, Paladine Combine.  The payments claimed to support the              
          deductions were made to Paul, allegedly to be forwarded to                  
          Paladine Combine.  Paul refused to provide an address, a                    
          telephone number, or the name of an individual associated with              
          Paladine Combine.  Petitioner testified that he did not fill out            
          a loan application or provide a financial statement to secure the           
          loan.  Petitioner produced only a note in which Paladine Combine            
          agreed to pay principal and interest to petitioner.                         
               In support of certain travel expenses that were deducted,              
          petitioner called Joseph D. Gordon (Gordon) to testify.  Gordon             
          claimed to have assisted petitioner in “finding funds” and with a           
          personal bankruptcy problem.  Petitioner and Gordon traveled to             
          Las Vegas, Nevada, during 1996 and purportedly had a meeting at a           
          casino with a prospective lender.  Gordon’s testimony was                   
          questionable, was lacking in specifics, and was insufficient to             
          support a finding of business purpose for the travel expenses.              






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