- 22 - expenditures, many of which appear to reflect significant elements of personal consumption. Even if we were to assume, arguendo, that some of these expenditures were for items used aboard petitioner’s aircraft, this fact would not in and of itself substantiate business purpose, for as previously discussed, in the criminal investigation petitioner admitted that he used his aircraft for personal purposes. Even if we were to assume, arguendo, that some of these expenditures were for legitimate business purposes, the evidentiary record does not provide a rational basis for identifying or estimating such expenditures to the exclusion of the personal expenditures that we believe are included in these unagreed expenses. Petitioner has failed to establish entitlement to deductions he claims for supplies. 5. Labor Expenses Petitioner seeks to deduct as business expenses two checks totaling $306 drawn on Romer & Co.’s checking account and made payable to “Jennie Sheffers” (Sheffers). Petitioner contends that he gave the checks to Sheffers as payment for washing and waxing his aircraft. The checks themselves do not have any notation as to why they were made payable to Sheffers. Besides petitioner’s own self-serving testimony, we have no corroborative evidence as to why these checks were drawn. We find it telling that these checks were drawn on Romer & Co.’s checking account rather than on the checking account set up for petitioner’sPage: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 Next
Last modified: May 25, 2011