Midwest Industrial Supply, Inc. - Page 7

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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   
               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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