James G. LeBloch and Cathy Michelsen LeBloch - Page 40




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          received into evidence through the parties’ stipulation that the            
          exhibit reflects “documents which Petitioners contend pertain to            
          overnight business meal expense for taxable year 1999”.  Exhibit            
          112-P has approximately 20 pages, and petitioners have not                  
          organized or presented the “documents” included therein (mainly             
          photocopies of receipts) in any manner that persuades us that any           
          of the expenses reflected in this exhibit are properly deductible           
          by petitioners as “meals”.  See Romer v. Commissioner, T.C. Memo.           
          2001-168.  Nor do petitioners in their posttrial opening brief              
          make any concerted attempt to persuade us that they have                    
          satisfied the requirements for such deductibility; petitioners’             
          entire argument on this point is that “Expenses incurred are                
          substantiated in Exhibit 124-P.  Total expenses are $9,789.”  We            
          sustain respondent’s determination that petitioners are not                 
          entitled to deduct these claimed expenses.                                  
          E.  Epilogue                                                                
               We have considered all of the parties’ arguments, and all              
          arguments not discussed herein have been rejected as moot,                  
          irrelevant, or without merit.                                               
                                                  Decision will be entered            
                                             under Rule 155.                          












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