- 48 - business expenses. Petitioners argue that Elvin, on behalf of YOC, entertained potential customers, some of whom purchased new automobiles from YOC on an annual basis. Petitioners argue that General Motors encouraged Elvin to entertain potential customers and that entertainment was a necessary expense to attract purchasers of high-priced Cadillac automobiles. Respondent argues that petitioners have not substantiated the business, as opposed to the personal, nature of any of the claimed travel and entertainment expenses that respondent disallowed and treated as constructive dividends to Elvin. Petitioners have not offered any documentary evidence or other credible substantiation to support the business nature of the claimed travel and entertainment expenses disallowed by respondent. We sustain respondent's determination that for 1983, 1984, and 1985, the claimed travel and entertainment expenses of $22,014, $14,012, and $22,080, respectively, are to be disallowed, and Elvin is to be treated as receiving constructive dividends for the same years and in the same amounts. Additional Personal Expenses of Elvin Paid by YOC -- Claimed Business Expenses and Constructive Dividends Petitioners make no persuasive argument and offer no credible evidence that any of the expenses in question under this category (1983 -- $65,487; 1984 -- $43,495; 1985 -- $74,798; and 1986 -- $15,136) qualify as valid business expenses of YOC. ManyPage: Previous 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 Next
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