- 8 - 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.”Page: Previous 1 2 3 4 5 6 7 8 9 10 11 NextLast modified: March 27, 2008