Winston Knauss - Page 25

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          produces only a minor adjustment, because the available evidence            
          indicates that only $75 in income from this source was included             
          in respondent’s reconstruction of 1994-96 gross receipts (and               
          petitioner has failed to show inclusion in his income in any                
          other year).  We therefore conclude that the downward adjustment            
          in respondent’s reconstruction that is appropriate in light of              
          petitioner’s evidence is capped at $75.  Thus, we conclude that             
          petitioner has shown error in respondent’s reconstruction of 1996           
          gross receipts, in that it is overstated by $75.                            
               Petitioner has not alleged or shown any other error in                 
          respondent’s reconstruction of the gross receipts from                      
          petitioner’s yacht charter business in 1994, 1995, or 1996.  We             
          accordingly sustain respondent’s determination of unreported                
          charter income in those years, except to the extent of $16,662 in           
          1994 and $75 in 1996.                                                       
          Disallowed Deductions of WDI                                                
               Taxpayers may deduct the ordinary and necessary expenses of            
          carrying on a trade or business.  Sec. 162.  Expenses incurred by           
          a corporation for the personal benefit of its shareholders are              
          not deductible.  Intl. Trading Co. v. Commissioner, 275 F.2d 578,           
          585 (7th Cir. 1960), affg. T.C. Memo. 1958-104.  Further, a                 
          taxpayer may not deduct the business expenses of another                    
          taxpayer.  Welch v. Helvering, 290 U.S. 111, 114 (1933).  The               
          burden of proof with respect to deductions claimed rests on the             






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