Nicholas M. Romer - Page 23




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          aviation activities.  Petitioner admitted at trial that he used             
          Romer & Co.’s checking account to pay his personal expenses.                
          Thus, the evidence does not rule out the possibility that                   
          petitioner made the checks at issue payable to Sheffers to cover            
          personal expenses.  Petitioner has failed to substantiate                   
          business purpose for these payments.                                        
               6.  Pilot Expenses                                                     
               Petitioner contends that pilots who flew his aircraft                  
          generally charged their expenses to his credit card.  He also               
          contends that he reimbursed one pilot named Adrian Grimm (Grimm)            
          $2,010 by paying that amount directly to Grimm’s creditors.                 
          Petitioner claims he is entitled to deduct the $2,010 as a                  
          business expense under section 162.                                         
               In support of his claim, petitioner introduced into evidence           
          five checks made payable to parties that petitioner contends were           
          Grimm’s creditors.  While the checks themselves make no mention             
          of Grimm, the notations in petitioner’s check register contain              
          such statements as “Adrian Grimm-Fuel & Expense”, “for Adrian”,             
          or just “Adrian”.                                                           
               Petitioner has failed adequately to establish that the                 
          payments in question were for pilot services rendered.                      
              7.  Rent                                                               
               Petitioner seeks a deduction for a check in the amount of              
          $200 for hangar rent for June 1989.  On the basis of the                    
          documentary evidence in the record, we conclude that petitioner             





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