William Lenihan - Page 21

                                       - 21 -                                         
          truck expenses, insurance, legal and professional services,                 
          office expenses, supplies, taxes and licenses, travel, meals and            
          entertainment, and other expenses totaling $21,530.  The parties            
          have jointly stipulated four exhibits, totaling 55 pages,                   
          containing documents that petitioner produced with respect to his           
          claimed Schedule C expenses.  Respectively, the four exhibits               
          contain documents that petitioner produced with respect to his              
          claimed Schedule C advertising, car and truck, insurance, travel,           
          and meals and entertainment expenses.  Respondent does not                  
          stipulate that the documents substantiate the claimed expenses.             
          The documents consist of photocopies of receipts from the U.S.              
          Postal Service, bills with respect to automobile repairs, the               
          faces of personal checks, insurance company bills, airline                  
          itineraries, hotel confirmations and bills, a railroad ticket,              
          account statements from an athletic club and a country club, a              
          statement from a financial institution, and other miscellaneous             
          documents.  We have examined the documents and, although they               
          indicate that petitioner spent, or at least was billed for, the             
          amounts shown, we cannot conclude that any or all of those                  
          amounts were expended in connection with a consulting or any                
          other business activity of petitioner’s.  Indeed, petitioner has            
          provided no evidence describing any consulting work that he                 
          engaged in during 2000.4  Moreover, in type and amount, the                 


               4  On brief, without reference to anything in the record to            
                                                             (continued...)           




Page:  Previous  11  12  13  14  15  16  17  18  19  20  21  22  23  24  25  26  27  28  29  30  Next

Last modified: May 25, 2011