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barbecue. Respondent disallowed these amounts in their entirety.
Many of the alleged promotion expenses claimed by
petitioner are actually entertainment expenses, subject to the
strict substantiation requirements of section 274(d). See supra
pp. 9-10. For 1991 and 1992, petitioner's alleged business
promotions include a $500 check made out to a "Dick Howard" for a
statue petitioner purchased at a Rotary auction which he
attended. Petitioner alleges that this purchase was related to
his business because he donated the statute back to the Rotary
Club in TSI's name for re-auctioning, which petitioner asserts
created both name recognition and goodwill for TSI. The other
items deducted by petitioner include sponsorship fees to various
rodeos, tickets to a benefit, golf tournament fees, and similar
expenses.
Petitioners have failed to show how any of the expenses
incurred for such activities actually afforded petitioner
contacts with possible clients or had any direct relationship to
the production of income. Ferrer v. Commissioner, 50 T.C. at
185. Thus, we affirm respondent's determination on this issue.
H. Computer Charges
For 1991 and 1992, petitioner deducted computer charges of
$1,051 and $1,598, respectively. Respondent disallowed these
expenses in full. On this issue, we find for petitioner.
At trial, petitioner testified that these expenses, which
were incurred in connection with his investigation and
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