- 8 - time for the purchase and transfer of the manufactured home to be compensation. At trial, petitioner asserted that Ms. Brownell “signed off her right to sue” him in section 16 of the permanent stipulation. He argues that this provision is evidence that there was an agreement that Ms. Brownell would accept the manufactured home in exchange for any past claim for compensation for her services. We find nothing in this provision to support petitioner’s argument. This provision was one of numerous provisions in the permanent stipulation covering issues ranging from paternity and custody of the children to the property interests of petitioner and Ms. Brownell. There is no indication that this provision was in any way connected with the provision granting Ms. Brownell the right to the manufactured home, nor is there any indication that it was intended in any manner to waive a claim by Ms. Brownell to sue for compensation for past services. We conclude that petitioner purchased the manufactured home in order to fulfill the terms of the permanent stipulation he entered into with Ms. Brownell, and that the purchase was a personal expense incurred in connection with his relationship with Ms. Brownell, as well as petitioner’s own children. Consequently, the purchase is a nondeductible expense pursuant to section 262(a) and not an ordinary and necessary business expense.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011