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as a result of its sponsorship of Sussex Farm. These claims are unpersuasive
for reasons we address below.
First, Mr. Vitale testified, and respondent has stipulated, that
petitioner's name was announced at shows as the sponsor of Sussex Farm's
horses. Mr. Vitale has not shown, however, that these loudspeaker
announcements were helpful to petitioner's business. He did not testify that
the loudspeaker announcements contained any information beyond petitioner's
name (e.g., information about petitioner's products or the nature of its
business) or that such announcements were reasonably calculated to help, or
did help, petitioner's business. See, e.g., Schulz v. Commissioner, 16 T.C.
401 (1951) (concluding that a watchmaker-jeweler named Schulz could not deduct
the costs of showing a horse called Schulztime, because the watchmaker did not
advertise his business in the show program and failed to establish that the
expenses were reasonably calculated to publicize or otherwise benefit his
business).
Second, Mr. Vitale testified that petitioner had placed advertisements
in the programs of a couple of shows. Petitioner did not, however, submit
copies of any such advertisements. We are not convinced that petitioner
placed these advertisements. Petitioner did submit a copy of an advertisement
published in an equestrian magazine entitled "The Chronicle of the Horse" that
referred to two Sussex Farm horses. The magazine, however, was dated August
24, 1990--after the period in issue and during the period when petitioner was
under audit.
Third, Mr. Vitale testified that petitioner received a general
contractor's request for a price quotation regarding one of petitioner's
products. After receiving this request, Mr. Vitale wrote a letter dated April
11, 1994, asking the general contractor to indicate in writing that he
contacted petitioner "as a result of Midwest's advertising in the equestrian
field." In reply, the general contractor wrote a letter to Mr. Vitale dated
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