Samuel S. and Laura M. Pinkney - Page 9

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          Roderick are of doubtful accuracy.  To the extent such payments             
          were made, petitioner did not keep a written log of Roderick’s              
          hours or duties, nor did he explain how he determined Roderick’s            
          compensation.  As a result, it is not clear whether the payments            
          represent reasonable compensation for the services, if any, that            
          Roderick performed.  Roderick’s failure to report the $5,460                
          casts further doubt on the deductibility of the payments, as does           
          petitioner’s failure to timely file information returns.  See               
          Haeder v. Commissioner, supra; Martens v. Commissioner, supra.              
          Accordingly, petitioners have failed to meet their burden of                
          proof, and respondent’s determination is sustained to the extent            
          of $24,510.89.                                                              
               C.  Bad Debt Expense                                                   
               In general, section 166(a)(1) allows as a deduction any debt           
          which becomes worthless within the taxable year.  Business debts            
          may be deducted against ordinary income to the extent that such             
          debts become wholly or partially worthless during the year.                 
          Nonbusiness debts also may be deducted, but only in the same                
          manner as short-term capital losses, and only if the debts are              
          wholly worthless in the year claimed.  Sec. 166(d); sec.                    
          1.166-5(a)(2), Income Tax Regs.  Section 166(d)(2) provides                 
          generally that a “nonbusiness debt” means a debt other than a               
          debt created or acquired in connection with a trade or business             







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