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has adequately substantiated and is entitled to the $200
deduction at issue.
8. Fees
Petitioner seeks deductions for three payments in 1989 in
the respective amounts of $10, $110, and $10,000, and three
payments in 1990 in the respective amounts of $6, $59, and $91
for “fees”.
Petitioner has offered no evidence regarding the $10 and
$110 payments in 1989, nor any of the three payments in 1990.
Consequently, we deem petitioner to have conceded that these
items are not deductible. As for the alleged $10,000 payment, it
appears--for reasons that are unclear from the record--that
petitioner initially paid this amount to Cross, who at some
undetermined later date refunded most if not all of it to
petitioner.13 Petitioner has failed to show that he is entitled
to deduct the alleged $10,000 payment.
9. Miscellaneous Cash Expenditures
Petitioner seeks to deduct various cash expenditures that he
allegedly made during the subject years for, among other things,
aviation maps, charts, hotels, parts, and apartment furnishings.
Respondent disallowed petitioner’s deductions for these cash
expenditures.
13 Petitioner admitted that a portion of the $10,000 was
refunded to him but could not recall the amount. Cross testified
that he refunded “pretty much the whole thing” to petitioner.
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