Joseph A. and Sari F. Deihl - Page 63

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          there by the Irish government”.  He likewise asserted globally              
          that he had never taken a vacation or an airline trip for                   
          personal reasons during the years in issue.  No details of any of           
          the trips were offered.                                                     
               Leaving aside other potentially applicable limitations, the            
          Court observes that any deduction for travel would at minimum               
          require compliance with the strict substantiation provisions of             
          section 274(d).  Yet Mr. Deihl’s testimony in this regard, not to           
          mention the uninformative credit card documents, falls woefully             
          short.  We do not even know the dates of the travel.  No                    
          deduction is permitted.                                                     
               K.  Contributions                                                      
               Petitioners’ records or testimony link several expenditures            
          to the idea of a contribution and/or charitable entity.  For                
          example, concerning an $800 May 6, 1996, Mayor check to New                 
          Arizona Family characterized in the general ledger as for “Golf             
          Registration”, Mr. Deihl testified:  “The New Arizona Families,             
          it’s a charity here in town that we helped co-sponsor and                   
          participated in a golf outing with them.”  Petitioners sought to            
          deduct the amount under training, meetings, and/or conventions.             
          A $1,000 June 3, 1997, KareMor charge to Phoenix Zoo was labeled            
          on credit card statements as “ADMISSION/TICKETS”, but Mrs. Deihl            
          testified:  “I would assume it was a donation to the Phoenix                
          Zoo.”  The amount was claimed under promotion.                              






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