Nicholas M. Romer - Page 13




                                       - 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