-12- business (essentially as a form of advertising or promotional expense). The basis for this contention is that his socializing at art functions and his activity as an artist afforded him an opportunity to meet potential clients and promote his accounting practice. To prevail on this theory, petitioner must show that the expenditures were made primarily for business purposes. Hahn v. Commissioner, T.C. Memo. 1979-429. Also, it must be shown that there is a proximate rather than a remote or incidental relationship between the expenditures and the business concerned. Henry v. Commissioner, 36 T.C. 879 (1961); Boomershine v. Commissioner, T.C. Memo. 1987-384; Hahn v. Commissioner, supra. The mere fact that engaging in an activity affords contact with possible future customers or clients is in and of itself insufficient to justify deducting the cost of the activity as a business expense. Hahn v. Commissioner, supra. Petitioner has not shown a business purpose for the expenditures or that there was a proximate relationship between the expenditures from his artist activity and his accounting business. Accordingly, none of these expenditures are deductible under section 162 as ordinary and necessary business expenses of his accounting business. Substantiation Although petitioner's artist activity was "not engaged in for profit" within the meaning of section 183(c), petitioner mayPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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