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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. The
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