World of Service, Inc. - Page 11

                                       - 11 -                                         
             Great deducted $166,162 and $105,905 for its FYE July 31,                
           1983 and 1984, for film and video fees.  These deductions were             
           allegedly for inspirational films that had been made by                    
           individuals, such as Vince Lombardi.  Great's deduction was                
           based on an alleged agreement, under which Great was to pay 3              
           percent of sales for the rental of the films.  Because Great               
           was on the accrual method of accounting, the amounts were                  
           projected, and deductions were taken on Great's tax returns.               
           Some of the films were otherwise available and were in the                 
           public domain.  Rights to the films were allegedly in a company            
           in Barbados.  Great did not make any payments with regard to               
           the alleged film rentals.  Respondent disallowed these amounts             
           because they were not incurred.  Great, for its years ended                
           July 31, 1983 and 1984, deducted $330,536 and $529,321 for                 
           seminars, and respondent disallowed $10,907 and $17,468,                   
           respectively.  Respondent's agent was not provided with any                
           documentation for the seminar deductions for the years at                  
           issue.  The agent concluded that 96.7 percent was allowable in             
           each year based on prior years' audit experience where                     
           documentation was provided and audited.  Petitioners did not               
           provide documentation at trial that would show that                        
           respondent's determination was in error.                                   
             Great, for its FYE July 31, 1983, deducted $170,147 for                  
           travel, meals, and entertainment.  Respondent reviewed                     
           $65,298.85 of the claimed amount and disallowed $19,382.46, or             




Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011