Niv v. Comm'r
United States Tax Court
R disallowed certain business expense deductions P claimed on his 2006 and 2007 tax return and determined deficiencies in income tax, additions to tax pursuant to I.R.C. sec. 6651(a)(1) for failing to timely file the 2006 and 2007 tax returns, and accuracy-related penalties under I.R.C. sec. 6662(a) for P's 2006 and 2007 tax years. Held: P did not substantiate expense deductions for travel, meals, entertainment, and car expenses.
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R disallowed certain business expense deductions P claimed on his 2006 and 2007 tax return and determined deficiencies in income tax, additions to tax pursuant to I.R.C. sec. 6651(a)(1) for failing to timely file the 2006 and 2007 tax returns, and accuracy-related penalties under I.R.C. sec. 6662(a) for P's 2006 and 2007 tax years. Held: P did not substantiate expense deductions for travel, meals, entertainment, and car expenses. Held, further, P is entitled to a portion of his claimed deductions for promotion and materials costs in connection with his real estate business for 2006 and 2007.…
1Opinion of the Court
RON NIV, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Niv v. Comm'r
Docket No. 9041-11.
United States Tax Court
T.C. Memo 2013-82; 2013 Tax Ct. Memo LEXIS 84; 105 T.C.M. (CCH) 1512;
March 21, 2013, Filed
Decision will be entered under Rule 155.
R disallowed certain business expense deductions P claimed on his 2006 and 2007 tax return and determined deficiencies in income tax, additions to tax pursuant to I.R.C. sec. 6651(a)(1) for failing to timely file the 2006 and 2007 tax returns, and accuracy-related penalties under I.R.C. sec. 6662(a) for P's 2006 and 2007 tax years.
Held: P did…
2Cases cited19 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- HIGBEE v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001
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