- 14 - $2,000 per month, for a total of $24,000. Having no basis upon which to conclude that greater amounts were paid, we sustain respondent on this issue. D. Payments Due on Account of Violations The record contains documentation relating to amounts assessed by local, State, and Federal agencies on account of various statutory and regulatory violations. Although it is not clear whether petitioners deducted these amounts on their return and, if so, under what classification of expense, we assume that inclusion of the documents in the record is based on petitioners’ belief that they support a deduction. At the outset, we emphasize that section 162(f) explicitly provides that no deduction shall be allowed “for any fine or similar penalty paid to a government for the violation of any law.” Accordingly, to the extent that the aforementioned amounts are of a type within the purview of section 162(f), as the majority would appear clearly to be, payment thereof is nondeductible in any event. However, for the sake of completeness, we deal briefly with additional reasons why the documentation offered fails to support increased deductions. First, the evidence includes bills from the Los Angeles Police Department for amounts imposed due to violations of section 103.206 of the Los Angeles Municipal Code “for excessive false alarms without the required alarm permit”. PetitionersPage: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
Last modified: May 25, 2011