Michael J. Rovell - Page 7

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          rendered with respect to petitioner’s income tax issues and                 
          petitioner’s personal life (i.e., divorce proceeding).  Moreover,           
          Mr. Moss’s letters are likewise ambiguous as to what portion of             
          the legal services at issue was rendered strictly for                       
          petitioner’s income tax problems.  Therefore, because it is                 
          impossible to determine the nature of these legal services, and             
          due to petitioner’s failure to provide additional information               
          with respect to the nature of these services after the Court                
          ordered the record to be held open for that purpose, we sustain             
          respondent with respect to the disallowance of petitioner’s                 
          deduction for tax preparation fees.                                         
               Third, and with respect to the deduction taken for                     
          petitioner’s other miscellaneous business expenses for                      
          entertaining clients and promoting his legal practice, petitioner           
          failed to provide the Court with any documentation or, for that             
          matter, credible testimony as to the nature and type of these               
          expenses.  Section 274(a) provides that no deduction will be                
          allowed for items considered entertainment unless the taxpayer              
          establishes that the item was related to the active conduct of              
          the taxpayer’s trade or business.  Sec. 274(a)(1).  Moreover,               
          section 274(d)(2) requires that the taxpayer substantiate                   
          entertainment expenses by showing adequate records or providing             
          sufficient evidence corroborating the taxpayer’s own statement.             
          In this case, petitioner’s testimony that he maintains a national           

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