- -15
2(e)(4), Income Tax Regs. We disagree that petitioner has
established by these receipts that 50 percent of the total
calendar days of his use of the country club during a taxable
year were days of business use. Petitioner's claim is based on
food and drink charges, which respondent agreed he was entitled
to deduct. However, section 1.274-2(e)(4), Income Tax Regs.,
requires that the taxpayer show that he had a "substantial and
bona fide business discussion", within the meaning of section
1.274-2(d)(3)(i)(a), Income Tax Regs., to count the day as a
business use. Furthermore, there is no showing that petitioner
and his family did not use the club on other days for golf,
tennis, swimming, or other purposes which would not show on a
food or beverage tab. The largest single bill in 1987 is for a
wedding reception which petitioners consider use for 1 day. It
is inconceivable that such an affair would not have required a
number of other days of visits to the country club in planning
the affair. The fact that respondent agreed that the relatively
small amounts, as compared to other 1987 country club charges,
shown on the thirty-three receipts were deductible by petitioner
does not establish that the dues paid to the country club were
ordinary and necessary expenditures under section 162. Randall
v. Commissioner, supra. Petitioner had a family membership in
the club. He has made no showing of how much his wife and
children used the country club in 1987, and, other than his
totally unsupported testimony that 50 percent of the use of the
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