- 9 - that the vast majority of them were either for nondeductible personal items or for transportation and entertainment and did not meet the more stringent requirements of section 274(d). Petitioner, on the other hand, contends that most of the expenditures represented by these documents were in connection with his real estate business activity. The credit card records, which are admittedly incomplete, totaled $11,179.74 for the 2-year period (1992-93). Of the $11,179.74: $9,234.43 was for 1992; $1,679.02 was for 1993; and $266.29 was not differentiated as to the year. The Court found respondent’s review of these items to be hypercritical. Other than items that are clearly for travel and entertainment, respondent did not give petitioner the benefit of the doubt. For example, on a charge for the changing of a lock, respondent in denying a deduction commented: “Why did lock(s) need to be changed”? In situations where the payment of the credit card by one of petitioner’s related corporate entities had been determined to be income, respondent in denying a deduction, commented: “Bus purpose--already acctd above??”3 On several purchases of hardware, respondent in denying a deduction commented: “Bus purpose--vague”. 3 We assume that respondent concluded that these expenditures that were used to reconstruct petitioner’s income were personal in nature and not deductible as a business expense.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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