- 17 -
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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