T.C. Memo. 2004-41
UNITED STATES TAX COURT
ALEC JEFFREY MEGIBOW, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8369-02. Filed February 19, 2004.
Respondent determined deficiencies for
petitioner’s 1997, 1998, and 1999 taxable years based
primarily on the disallowance of amounts claimed as
business expense deductions.
Held: Because petitioner failed to substantiate
claimed deductions, he is liable for income tax
deficiencies for 1997, 1998, and 1999.
Held, further, petitioner is liable for sec.
6662(a), I.R.C., accuracy-related penalties with
respect to the years in issue.
Anthony M. Bentley, for petitioner.
D. Sean McMahon, for respondent.
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