Efrain J. and Josefina Xuncax - Page 14




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          $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”.  Petitioners               






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