Gizzi v. Commissioner
United States Tax Court
Petitioner deducted as business expenses his costs of certain entertainment, travel, business gifts, and club dues. He had maintained adequate records of these expenses, but his records were inadvertently thrown out.
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Petitioner deducted as business expenses his costs of certain entertainment, travel, business gifts, and club dues. He had maintained adequate records of these expenses, but his records were inadvertently thrown out. Held, the records were not lost due to a casualty beyond petitioner's control, and therefore he was not relieved of the substantiation requirements of sec. 274. Sec. 1.274-5(c)(5), Income Tax Regs.Held, further, even if the loss of the records had been due to a casualty beyond his control, petitioner did not reasonably reconstruct his claimed expenses, and is not entitled to the…
1Opinion of the Court
Joe F. and Ann Gizzi, Petitioners v. Commissioner of Internal Revenue, Respondent
Gizzi v. Commissioner
Docket No. 8854-72
United States Tax Court
65 T.C. 342; 1975 U.S. Tax Ct. LEXIS 40;
November 4, 1975, Filed
Decision will be entered for the respondent.
Petitioner deducted as business expenses his costs of certain entertainment, travel, business gifts, and club dues. He had maintained adequate records of these expenses, but his records were inadvertently thrown out. Held, the records were not lost due to a casualty beyond petitioner's control, and therefore he was not relieved of the…
2Cases cited4 opinions
- Gizzi v. CommissionerUnited States Tax Court · 1975
- Blackburn v. CommissionerUnited States Tax Court · 1973
- Seckel v. CommissionerUnited States Tax Court · 1974
- Silver v. CommissionerUnited States Tax Court · 1972