- 13 - the conduct of his various business activities problematical or illegal–-do nothing to enhance his credibility. Petitioner’s demeanor on the stand, his admitted criminal conduct, and (as discussed in more detail infra) impeaching evidence originating from his criminal investigation all combine to undermine his credibility severely. Petitioner’s testimony struck us as in good part invention, contrived to meet the needs of trial according to his self-professed knowledge (if belated appreciation) of the applicable legal requirements. In short, we are unable to give petitioner’s testimony much weight. 1. Aviation Fuel Petitioner seeks to deduct expenses, not claimed on his return, that he allegedly incurred for aviation fuel. The parties agree that petitioner is entitled to deductions for fuel expenses paid by debits on petitioner’s Great Lakes account, by check, and by his Visa credit card (the credit card) for taxable years 1989, 1990, and 1991 in the respective aggregate amounts of $4,926, $11,328, and $612. The parties disagree as to whether petitioner is entitled to deductions for aviation fuel expenditures that petitioner alleges he made in cash, in the amounts of $13,803, $27,287, and $3,276, for the years 1989, 1990, and 1991, respectively. The parties also disagree as to whether petitioner is entitled to deductions for fuel expenses charged to petitioner’s credit card in taxable years 1990 and 1991 in the amounts of $4,912 and $710, respectively.Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
Last modified: May 25, 2011