Gerald Patrick Dietrick Anita Lea Dietrick v. Commissioner of Internal Revenue

BOYCE F. MARTIN, Jr., Circuit Judge.

The taxpayers 1 appeal the Tax Court’s decision finding deficiencies in his 1980 and 1982 returns in the amounts of $70,864.45 and $38,421.03. The following issues are raised on appeal: were the expenses paid by the taxpayer on behalf of a closely held corporation to “protect or promote” his business? Was the taxpayer partially reimbursed through an incorrect deduction for expenses he paid on behalf of a closely held corporation? Consideration of these issues involves a review of the Tax Court’s findings of fact.

We review the Tax Court’s finding of fact…