- 9 -
documents in the record before this Court. Petitioner claims
that Merrill Lynch will not turn over the documents. Respondent
notified petitioner of the possibility of subpoenaing the
documents and continuing this case in an attempt to obtain them.
Petitioner did not avail himself of the opportunity either to
continue this case or to subpoena the alleged documents.
Moreover, petitioner testified that he could not explain, as
to each entertainment expenditure, who he met with or what the
expense was incurred for, and he could not explain as to airline
expenditures what was the objective of the trip or the
destination. As to the other claimed job expenses and
miscellaneous deductions, petitioner stated: “It’d be impossible
to give * * * the exact name and prospect” for each expenditure.
We have taken into consideration petitioner’s testimony and
incomplete records, and we conclude that petitioner failed to
satisfy the requirements of sections 162 and 274 as to any
expenditures in excess of the $19,285 respondent conceded.
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
under Rule 155.
Page: Previous 1 2 3 4 5 6 7 8 9 10
Last modified: May 25, 2011