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receipt that shows the cost of the dinner, plus tip (total
$59.20), marked “client meeting--Brennan”.2
There are other unexplained irregularities in the documents
that petitioner produced to support the disallowed deductions.
One receipt for a purchase of an item from Liberty Leather in
Torrence, California, is dated in 2001 and signed by someone
other than petitioner. Supermarket receipts marked as “training”
expenses for Wise employees include expenditures for items the
deduction of which would, without explanation, seem to be
prohibited by section 262(a).3 We could go on and on but see
little point in doing so. The many duplications and other
irregularities in the records that petitioner produced to support
the deductions claimed for expenses other than for commissions
and fees lead us to conclude that the records are unreliable.
Because petitioner has otherwise failed to substantiate the
deductions for those expenses, respondent’s disallowances of
those deductions are sustained.
2. Deduction for Commission and Fees Expenses
Trust checking account statements demonstrate that $28,353
($30,067 minus $1,714) of the $30,067 “override” commissions was
transferred from petitioner’s joint checking account to Wise’s
2 This pattern is repeated numerous times in the exhibits.
3 Sec. 262(a) provides in part that “no deduction shall be
allowed for personal, living, or family expenses.”
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Last modified: March 27, 2008