Creed J. Pearson - Page 6




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          seeks or shown that he has maintained sufficient records.  Sec.             
          7491(a)(2)(A) and (B).                                                      
               In his petition, petitioner claimed that respondent erred by           
          not computing his deductions for Schedule C expenses, Schedule A            
          interest, charitable contributions, and property taxes paid                 
          during the years in issue, but he did not state how much these              
          expenses amounted to.  As evidence that he is entitled to                   
          deductions, petitioner introduced two summaries of his expenses             
          during the years in issue.  The summaries contain general                   
          captions such as “PHONE”, “DONATIONS”, and “AM EXP GOLD”, the               
          amounts of the expenses, and usually dates for each expense.                
          However, the summaries provide no indication of which expenses              
          were for business purposes and which were for personal purposes,            
          and it is not clear which of the expenses petitioner is seeking             
          to deduct.  Petitioner credibly testified that he paid                      
          commissions to business associates in exchange for referrals, and           
          the names of these associates match some of the captions on the             
          expense summaries.                                                          
               On the basis of this evidence and information that                     
          petitioner provided while negotiating with respondent, respondent           
          concedes that under section 162(a) petitioner is entitled to                
          $214,645, $122,520, $239,965, $82,986, and $29,904 of Schedule C            
          business expense deductions for commissions and FOIA request fees           
          paid for taxable years 1999, 2000, 2001, 2002, and 2003,                    







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