Tobias G. Ogu - Page 7

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          if one was, the cost thereof or the flight itinerary.  Regarding            
          the other enumerated expenses, petitioner claims to have paid in            
          cash; he also claims that in Nigeria hotels, restaurants, and               
          other purveyors of goods and services do not provide receipts.6             
               On his Schedule C for 2000, petitioner claimed a deduction             
          for “trade mission” in the amount of $6,975.  In this regard,               
          petitioner claims to have gone to Nigeria on another “trade                 
          mission” from December 25, 2000, to January 13, 2001.  The record           
          does not include any schedule of expenses that petitioner claims            
          to have incurred.  The record does include a flight itinerary               
          issued by a travel agency in Houston calling for the payment of             
          $1,930 and a passenger receipt showing a fare of “BULK” and tax             
          of $88.73.  No other documentation exists in the record;                    
          petitioner again claims to have paid his expenses in Nigeria in             
          cash.                                                                       
               At trial, petitioner testified that he went to Nigeria on              
          “trade missions” during the holiday season not because his family           
          was there (see infra I.D., note 8) but because:                             
               In Nigeria business is mostly done during December                     
               time.  Done during December time, because at that time                 
               you have gifts to give to people.  They’re happy.  So                  
               this is the only time they can talk to you.                            





               6  According to petitioner, “Everything in Nigeria is cash”            
          and “there is nothing like a receipt.”                                      





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