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$55,663.75, respectively.1 Further, respondent determined
accuracy-related penalties against petitioner under section
6662(a) in the amounts of $34,525.20 and $6,211.80 for 1998 and
1999, respectively.
The issues for decision are:
(1) Whether petitioner is entitled to a $435,000 charitable
contribution deduction for tax year 1998. We hold that he is
instead entitled to a charitable deduction of $12,713.28.
(2) whether petitioner is entitled to a theft loss
deduction of $2,221,668 for tax year 2000. We hold that he is
not.
(3) whether petitioner, through Global Trading Group (GTG),
an S corporation of which petitioner is the sole shareholder, is
entitled to travel, meal and entertainment business expense
deductions for tax year 1999 for an amount greater than the $437
allowed by respondent. We hold that he is not.
(4) whether petitioner, through GTG, may deduct travel and
meal expense deductions of $53,245 for the tax year 2000. We
hold he may not.
(5) whether petitioner, through GTG, is entitled to more
than $2,850 in rent deductions for tax year 1999. We hold that
he is not.
1Unless otherwise indicated, all section references are to
the Internal Revenue Code, and all Rule references are to the Tax
Court Rules of Practice and Procedure.
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