- 29 - increased by $22,000 to reflect the advances from suppliers claimed by petitioners. Petitioners now contend that credit card charges, in addition to those allowed by respondent, are deductible as business expenses. Respondent treated all payments on personal credit cards as personal living expenses. Petitioners argue that it was unreasonable for respondent to treat the payments in that manner. Petitioners claim that they are entitled to additional business expense deductions of $17,774.94 on JKY's 1990 return and $26,788.87 on JKY's 1991 return for expenses charged to personal credit cards. Petitioners have offered schedules of credit card charges prepared by Caufield that categorize each credit card expenditure. The underlying credit card statements are not part of the record in this case. Also, the schedules show that certain statements were not available at the time the schedule was created. Caufield testified at trial that he prepared the schedules and consulted Yoon only when Caufield was unclear as to the classification of a charge as business or personal. Numerous items claimed as business deductions by petitioners appear to be for travel and entertainment, i.e., restaurant charges and airline charges. Petitioners claim that 100 percent of these expenses is deductible, ignoring the 80-percent limit on deductibility under section 274(n). Furthermore, to prove entitlement to deductions for travel and entertainment expenses,Page: Previous 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 Next
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