- 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