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expenses related to the Centurion were not “ordinary and
necessary expenses paid or incurred during the taxable year in
carrying on any trade or business” of petitioner’s within the
meaning of section 162(a) and, accordingly, that none of
petitioner’s expenses related to the Centurion are deductible by
it under section 162(a). Cirelli v. Commissioner, 82 T.C. 335,
349-350 (1984); Am. Props., Inc. v. Commissioner, 28 T.C. 1100
(1957), affd. per curiam 262 F.2d 150 (9th Cir. 1958); see also
Carter v. Commissioner, T.C. Memo. 1978-202, affd. 645 F.2d 784
(9th Cir. 1981).
Even if petitioner did meet the requirements of section
162(a) as to those expenses, it would still not prevail. Under
section 274(a)(1)(B),7 deductions which otherwise would be
6(...continued)
mention of the filming of documentaries; the minutes stated that
the Centurion was “to be used for a general business office,
staff and client meetings, and corporate entertainment”.
(Emphasis added.) Petitioner’s petition to this Court also makes
no mention of the filming of documentaries; it alleges as to this
issue that “Expenses incurred by Petitioner during income tax
years ended August 31, 1998 and August 31, 1999 in connection
with maintaining an office at its principal place of business on
* * * [the Centurion] are fully deductible under Code Section
162(a) for each of said income tax years.” Petitioner made this
allegation pursuant to Rule 34(b)(4) and (5), which requires that
every petition to this Court contain “Clear and concise
assignments of each and every error which the petitioner alleges
to have been committed by the Commissioner in the determination
of the deficiency * * * [and] Clear and concise lettered
statements of the facts on which the petitioner bases the
assignments of error”.
7 Section 274(a)(1) provides in pertinent part:
(continued...)
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