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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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