N. Joseph Calarco - Page 23

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          of sections 274 and 280F for deducting his drama festival                   
          expenses by documenting the date, cost, and purpose of his visit.           
          But as we noted above, we do not credit petitioner’s travel log,            
          and so it does not support his position that he spent $171.31 in            
          Ann Arbor on business purposes on November 16, 1997.  As such, we           
          disallow that deduction.  The log does indicate, and we find to             
          be believable, an expense for $189.04 at the Courtyard Marriott             
          in Ann Arbor on March 16, 1997.  We allow that deduction.  His              
          estimates of cash expenditures at fast-food outlets and other               
          establishments do not meet the requirements of sec. 274, and are            
          thus disallowed.                                                            
          7.   Books, Recordings, Videos                                              
               Petitioner claimed deductions for books, recordings, and               
          video in the amount of $3,324.  His posttrial submission details            
          $4,358 of expenses in this category.  A number of these items,              
          however, must be fully disallowed or considered in a different              
          category.  These include expenses for software, video, and                  
          newspaper subscriptions.  The removal of these items results in             
          $2,440.25 for this category.                                                
               The category’s other expenses are more ambiguous.  Some are            
          no doubt legitimate, and respondent has not identified any                  
          specific legal theory for their disallowance.  But allowing all             
          the deductions would be ignoring some obvious questions raised by           
          a great number of nonspecific items, such as large drug store               
          receipts.  Under the Cohan rule, we may estimate the proper                 




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