Barry D. and Suzanne B. Whalley - Page 31

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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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