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of $18,508; (3) supplies of $139.50; (4) travel expenses of
$1,050; and (5) deductible meals and entertainment of $347.65.
The Schedule C listed the “Kirshner Content and related entities”
as the business name and the activity was listed as “Media
Content and Entertainment and Songs”. Respondent did not agree
to deductions for these expenses.
Petitioner argues he is entitled to claim the $7,118 as a
bad debt deduction as it relates to various expenses that were
incurred in 1994, 1995, and 1996, in connection with the
attempted financing for the various Kirshner entities. The
expenses were for travel, meals, and entertainment. Although not
explicitly stated, as the Court understands, petitioner believed
he had a contractual right to be reimbursed for these expenses
from Kirshner Global, Kirshner Content, and/or other Kirshner
entities. Since he was never reimbursed for these expenses,
petitioner contends his claim for reimbursement is an
uncollectible bad debt.
Respondent contends the expenses were not created or
incurred in connection with a trade or business and questions
whether petitioner had the right to be reimbursed for such
expenses, and, if so, whether the debts became uncollectible in
2000.
Section 166 allows a taxpayer a deduction for any business
debt which becomes wholly or partially worthless during the
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