- 6 - within the meaning of section 170(c). See, e.g., Dept. of Treas., Cumulative List of Organizations Described in Section 170(c) of the Internal Revenue Code of 1954, at 687 (1985). Mr. Kerrigan also testified that he and his wife made cash contributions to their local Catholic church when they attended Mass on Sundays. Petitioners produced no documentation to substantiate this, and Mr. Kerrigan's testimony was vague as to the amounts and frequency of these contributions. Respondent has already allowed petitioners $1,053 of cash contributions. Petitioners' evidence falls far short of justifying any additional amount. Advertising Expenses Mrs. Kerrigan claimed a Schedule C deduction for advertising expenses in the amount of $5,419. Of this amount, respondent allowed $1,445. Petitioners argue that Mrs. Kerrigan's expenses consisted of expenditures for signs, open houses, and "gifts" which Mrs. Kerrigan frequently purchased for her clients as an additional form of advertising. Mrs. Kerrigan's open house expenses included expenditures for plants and chocolates, while her business "gifts" ranged from children's toys to maternity clothes. At trial, petitioners presented Mrs. Kerrigan's business log for 1985, which contains numerous entries throughout the year, reflecting numerous expenditures for these items. ThePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
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