Gerry M. Griggs - Page 11

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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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