Nicholas M. Romer - Page 22




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          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’s                 





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