Nos. 88-1986, 88-1998.

881 F.2d 336 (1989)

Gerald Patrick DIETRICK; Anita Lea Dietrick, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided August 10, 1989.

Attorney(s) appearing for the Case

Stephen A. Kappers (argued), Robert J. Hollingsworth, Cors, Bassett, Kohlhepp, Halloran & Moran, Cincinnati, Ohio, for Gerald Patrick Dietrick and Anita Lea Dietrick.

William F. Nelson, I.R.S., Robert A. Bernstein, Kimberly S. Stanley (argued), U.S. Dept. of Justice, Tax Div. Appellate Section, Gary R. Allen, Acting Chief, William S. Rose, Jr., Asst. Atty. Gen., Dept. of Justice Tax Div., Washington, D.C., for C.I.R.

Before MARTIN and JONES, Circuit Judges, and COOK, District Judge.

BOYCE F. MARTIN, Jr., Circuit Judge.

The taxpayers1 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...

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