- 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