- 31 - 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 andPage: Previous 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 Next
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