- 12 -
Accordingly, pursuant to Cohan v. Commissioner, supra, the Court
allows petitioner $750 as church contributions for 2000.
With respect to the $870 carryover from prior years,
petitioner offered no evidence to establish the carryover. That
item, therefore, is disallowed. Likewise, regarding the $16,680
deducted on his 2001 tax return, petitioner offered neither
testimony nor documentation to substantiate the amount claimed.8
Therefore, the Court sustains respondent on this issue and
disallows the deduction in its entirety.
The fifth issue is a bad debt deduction of $10,000 claimed
by petitioner as a trade or business expense in connection with
his personal security activity. As noted earlier, petitioner
contends he incurred this expense when he was hired to provide
security for a rapper, DMX, on a tour of Africa. Because the
performer and petitioner’s entourage did not have the appropriate
documents to be in Africa, they were permitted to leave the
country only after petitioner paid $10,000. Petitioner deducted
this payment as a bad debt on his 2000 tax return. The Court
disagrees that such a payment would constitute a bad debt within
the meaning of section 166. To the extent, however, that the
payment otherwise constituted an expense incurred in connection
8 Petitioner alluded to the existence of a letter from
his church pertaining to his gifts during 2001 when he testified
as to his contributions for year 2000; however, he never offered
the letter into evidence, nor did he address it further.
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