- 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011