Barry D. and Suzanne B. Whalley - Page 17

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          expense and the taxpayer's business and the primary motive or               
          purpose for incurring the expense.  Henry v. Commissioner, 36               
          T.C. 879, 884 (1961).                                                       
               We now address each category of disallowed deductions                  
          independently.                                                              
               A. Advertising                                                         
               Petitioner deducted advertising expenses of $510 in 1991 and           
          $317 in 1992.  Respondent determined that petitioner was not                
          entitled to any deduction for advertising, but later conceded               
          that petitioner is entitled to deduct $200 for 1991 and $218 for            
          1992, which represent the costs of yellow page advertising in               
          connection with TSI.                                                        
               The balance of the 1991 advertising represents amounts made            
          out on TSR checks, not TSI checks, for admission fees to golf               
          tournaments that petitioner claims to have attended for                     
          networking purposes.  Petitioner testified that he went around,             
          talked, and gave out his business cards to people.  However, to             
          meet his burden of proof, petitioner must offer more than a                 
          general statement that such expenses were incurred in pursuit of            
          his business in order to sufficiently establish that the                    
          expenditures had a reasonably direct relationship to his                    
          business.  Ferrer v. Commissioner, 50 T.C. at 185.  In this case,           
          the evidence presented at trial fails to establish that                     
          petitioner's activities at the golf tournament actually had any             






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