Zabetti A. Pappas - Page 56




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          taxpayer to substantiate by adequate records or by sufficient               
          evidence to corroborate the taxpayer’s own testimony:  (a) The              
          amount of the expenditure, (b) the time and place of the                    
          expenditure, (c) the business purpose of the expenditure, and (d)           
          the business relationship to the taxpayer of the person being               
          entertained.                                                                
               For 1989, petitioner claims a business expense deduction of            
          $180 for the cost of meals billed through the Vassar Club.                  
          Inconsistencies between the handwritten and printed receipts from           
          the Vassar Club, however, prevent us from finding that she has              
          adequately substantiated the business meal deductions claimed.              
          Nor has she adequately demonstrated the business purposes of                
          claimed travel expenses totaling $343 for separate trips in 1989            
          to Florida and to Washington, D.C.                                          
               Petitioner also claims deductions in 1989 for $3,000 in                
          legal and professional fees paid to the law firm of Saltzman &              
          Holloran and to the Prentice-Hall Financial Service relating to             
          the incorporation of Real Services.  She also seeks to deduct the           
          filing fees charged for such incorporation.  Assuming arguendo              
          that the claimed expenses of incorporating a corporation found to           
          be a sham for tax purposes have a business purpose, these                   
          expenses would nevertheless not be deductible in 1989;19 these              

               19 Organizational expenses incurred and paid by a                      
          corporation can be amortized at its election over a 60-month                
                                                             (continued...)           





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