- 32 - were withheld, their pay was reported on a Form 1099, and the 1991 salary was paid in a lump sum to each. We conclude that respondent properly treated the payments to Dominique and Jonathan as nondeductible personal expenditures and indicia of fraud. Petitioner overstated deductions for travel, meals and entertainment expenses and failed to provide credible evidence to support such deductions at trial. During the examination of petitioners’ taxable years 1991 and 1992, petitioners’ representative provided Agent McCarter with a travel log prepared by Mr. Black which purported to show Mr. Black’s business travel for taxable years 1991 and 1992. Agent McCarter returned the log to petitioners’ representative because she could not read Mr. Black’s handwriting and requested a legible copy of the log or other documentation to support Mr. Black’s deductions. Neither Mr. Black nor his representatives ever provided a new travel log or any other evidence to support his deductions for business travel, meals, or entertainment. Agent McCarter concluded that, on the basis of the amounts of claimed travel deductions and Mr. Black’s use of the standard mileage rate, Mr. Black had to have driven 156,669 miles in 1991 and 181,692 miles in 1992, which averages 429 miles per day inPage: Previous 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 NextLast modified: March 27, 2008