Peter Showler - Page 9




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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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