Sherman J. Miller and Alice K. Miller - Page 6

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            with clients and potential clients in connection with his                                 
            insurance-prospecting activity.  The country club was also used                           
            by petitioners' family for a family wedding in 1987.  Petitioner                          
            treated various required charges at the country club, such as                             
            valet charges, ladies prize fee charges, and locker room charges,                         
            in the same manner he treated the charges for dues.  These                                
            charges were incurred by country club members regardless of                               
            whether the member actually used these services.  There were                              
            charges made by petitioner at the country club on 33 days during                          
            1987 which related to drinks or meals with prospective insurance                          
                  On their 1986 and 1987 Federal income tax returns,                                  
            petitioners deducted expenses for the 1986 van, the condominium,                          
            and meals and entertainment.  Petitioners claimed as deductions                           
            on their Federal income tax returns the following expenses which                          
            were stated to be related to petitioner's insurance activities in                         

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