- 35 -
Since we sustained respondent's income determination with
respect to the promotional accounts and the food show
disbursements, we do not need to address her remaining argument.
To reflect the foregoing,
Decision will be entered
under Rule 155.
11(...continued)
payments made by vendors other than Mr. Clawson were deductible;
accordingly, petitioner has conceded this issue. Cluck v.
Commissioner, 105 T.C. 324, 325 n.1 (1995); Money v.
Commissioner, 89 T.C. 46, 48 (1987). In any event, we would find
that petitioner has not substantiated its entitlement to such a
deduction, because it destroyed the records associated with such
disbursements and provided no other credible evidence
demonstrating its entitlement to deduct such amounts. Sec. 6001;
sec. 1.6001-1(a), Income Tax Regs.
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