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Q But are you claiming that’s also a business
expense?
A Until I determine what it is. Then I can
tell you. But if it’s in here, it’s a business
expense.
* * * * * * *
A * * * And again I state, business and
personal are one and the same for me.
Many of the items were charges at restaurants or hotels that were
not substantiated as required by section 274. Petitioner merely
reiterated the untenable claim that all of his activities were
business related and all of his expenses were tax deductible.
Inconsistent and Contradicted Claims
In responding to discovery, petitioner claimed that the bad
debt that was deducted on his tax return was from “work performed
on patients who failed to pay.” He testified in Court, however,
that the bad debt deduction was attributable to a $9,210 loan
that was made in 1992 to a personal friend, who was also a
dentist and who died in 1998.
In his responses to discovery, petitioner claimed that only
dental lab equipment was located at the Manor Place condominium.
He objected to questions relating to the lease and to his
residence. His bankruptcy filings, however, reported that all of
his household goods and furniture were at the condominium, and
petitioner conceded at trial that he, his children, and his
associates spent nights at the condominium. On his return,
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