- 10 - 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 thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011