Peter Showler - Page 8




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          for meals paid for by credit card or cash; (2) copies of receipts           
          from various retail stores or supermarkets for food, beverages,             
          and other household items; (3) copies of receipts from golf                 
          courses; (4) copies of receipts from cigar stores and other gift            
          shops; (5) copies of checking account statements showing payment            
          for items by debit card; (6) copies of canceled checks; and (7)             
          spreadsheets which appear to list some of the items reflected in            
          the first six categories of documents.                                      
               We begin by noting that the totals shown on the spreadsheets           
          for various categories of expenses do not match the deductions              
          claimed for those expenses on petitioner’s return.  Furthermore,            
          nothing has been submitted that ties the disallowed deductions              
          to specific copies of receipts, checks, or other documents that             
          have been admitted into evidence.                                           
               Careful review of the restaurant receipts demonstrates many            
          duplications.  The following two examples of such duplications              
          are representative of many others:  (1) The February 15, 2002,              
          dinner at Saddle Peak Lodge in Calabasas, California, shown on              
          one receipt for $159.13 that details the items consumed is                  
          duplicated by a receipt for $183.13 that summarizes the amount of           
          the dinner check, plus tip; and (2) a dinner receipt dated                  
          February 22, 2002, from Café Bellissimo, in Woodland Hills,                 
          California, showing items totaling $49.20 consumed by two                   
          individuals, marked “client meeting--Faupel”, is duplicated on a            







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