Timothy Dean Strong - Page 36

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          any argument on brief regarding the additional amount.                      
          Accordingly, respondent’s determination on the remaining claimed            
          deduction is sustained.                                                     
                         d.  Miscellaneous Expenses                                   
               As to SCC’s other deductions (i.e., entertainment,                     
          insurance, and rent), Mr. Strong was not able to proffer any                
          documentation to substantiate that the purpose of these expenses            
          was for business.  Mr. Strong attributes the lack of                        
          substantiation to two fires that resulted in the loss of his                
          receipts, but his general attitude regarding Federal income taxes           
          and his lack of credibility leave us with no reason to believe              
          receipts were ever maintained.                                              
               Even if we were persuaded that some portion of these                   
          expenses was for business purposes, Mr. Strong has not offered              
          any evidence that would support his allocation of expenses or               
          otherwise allow the Court to reach an alternate determination               
          under Cohan v. Commissioner, 39 F.2d 540, 543-544 (2d Cir. 1930).           
          Thus, with regard to these additional expenses for which there              
          are no adequate receipts, SCC’s claim fails for lack of                     
          substantiation.                                                             
          III.  Constructive Dividends to Mr. Strong                                  
               Respondent argues that the unreported business income of               
          SCC, measured by the deposits into account No. 893315300, is                
          taxable to Mr. Strong as constructive dividend income because Mr.           






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