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listed is $3,000 for Tony, Jennifer, and Karlas “ON EP TRIP TO P.
RICO”, on 2/11 through 2/14, at the rate of $250 per guard per
day. Third is $2,829 for 246 hours, at the rate of $11.50 per
hour, on 2/8/98 through 2/21/98, at the location “POST 2”.
Respondent allowed $2,829 of the $14,475 total amount as a
deduction and disallowed the remaining $11,646.
Other invoices from Michael Reed contained in the record
show locations “HOUSE” and “PLANT”, indicating a practice of
billing based on these two categories. In examination of the
above-described and less definitive invoice, it appears that
respondent, absent further explanation from petitioners, may
arbitrarily have allowed the lesser charge. Nonetheless, on the
basis of an invoice for the previous 2-week period, which as
corrected shows an identical 246 hour and 752 hour split for
locations “HOUSE” and “PLANT”, respectively, the Court is willing
to allow petitioners an additional $5,817 in security expenses
($8,646 - $2,829) as attributable to the corporate property.6
As to the costs incurred for security while traveling,
Mr. Deihl’s testimony convinces us that while a portion may
represent legitimate business expenses, many are far more
6 The Court notes that with respect to the only other 2-week
periods in 1998 for which invoices are in the record, the
documents fail to support a similar allocation either because all
charges are characterized as attributable to “HOUSE” or because
the two locations are listed without specifying the hours or the
charges for a particular location.
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