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to the status or existence of such demonstration stock
portfolios.
When the fees and the items charged to the credit cards are
analyzed as a whole, it appears that the credit cards were used
primarily for personal reasons, and the fees are proximately
related to the personal use. The fees shown in the credit card
statements can be roughly categorized as annual fees, cash
advance finance charges, general finance charges, late fees,
over-the-limit fees, check transaction fees, and Internet
connection charges. Some of the statements included charges for
personal items. When questioned at trial, petitioner admitted
that charges from merchants such as “drugstore.com”, “Kroger”,
and “York Photo Labs” were personal. Therefore, the commissions
and fees deductions are disallowed under section 262.
In sum, the Court sustains respondent’s determination, to
the extent not conceded by him, that petitioner is not entitled
to the deductions for traveling expenses, meals and entertainment
expenses, and other expenses claimed on Schedule C.
B. Charitable Contributions
Section 170(a) allows as a deduction a charitable
contribution, payment of which is made within the taxable year.
A charitable contribution includes a contribution or gift to or
for the use of a corporation, trust, community chest, fund, or
foundation organized and operated exclusively for religious,
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Last modified: May 25, 2011