Barney K. and Lindy W. Huang - Page 13

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          documents show that petitioners were involved in various                    
          investments, lawsuits, bankruptcies, and other legal matters, but           
          they do nothing to substantiate specific deductible expenses.               
          The documents which do show specific expenditures are with                  
          respect to the attorneys and the court reporting services noted             
          above.                                                                      
               Petitioners first argue that they are entitled to deduct               
          additional expenses paid to Mark Kirby and Brian Upchurch in                
          1995, and to Matthew Martin in 1996.  We hold that petitioners              
          are not entitled to these deductions because they have failed to            
          substantiate the payment of these expenses during the relevant              
          years.  Sec. 6001; sec. 1.6001-1(a), (e), Income Tax Regs.                  
               Petitioners next argue that they are entitled to deduct                
          additional expenses paid to the two court reporting services,               
          Janet Brown, and Brian Upchurch in 1996, and to Kirk Osborn in              
          1996 and 1997.  A portion of these expenses was incurred in                 
          connection with the secondary malpractice suit brought by                   
          petitioners.  The suit underlying the original malpractice claim            
          by petitioners dealt with several issues, including petitioners’            
          personal bankruptcy and their investment in Tara.  Because the              
          connection between petitioners’ investment in Tara and the                  
          secondary malpractice suit years after Tara’s existence is too              
          attenuated to ascertain; we are unable to estimate the portion of           
          these expenses which may be deductible versus the portion which             






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