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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.
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