Robert P. Petrocine - Page 9

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          interest expense because that interest payment related to the               
          $103,000 he received from Dean Witter, which petitioner claims he           
          used for investment purposes.                                               
               Petitioner has not established that he used the $103,000               
          loan proceeds for investment purposes.  Petitioner fails to make            
          any argument regarding the remaining $2,000 in claimed interest             
          expense.  Petitioner has failed in his burden of proof on this              
          issue.                                                                      
               We sustain respondent's disallowance of petitioner's $5,433            
          claimed investment interest expense deduction for 1991.                     

          1992 -- Claimed Business and Other Deductions                               
               Section 274(a) and (d) allows deductions for certain meal              
          and entertainment expenses, including dues for membership in                
          social clubs.  To be deductible, such expenses must be directly             
          related to taxpayers' active conduct of a trade or business.                
               With regard to business expenses for meals and                         
          entertainment, section 274(a) limits the deduction to those                 
          expenses incurred directly preceding or following a bona fide               
          business discussion relating to the taxpayers' active conduct of            
          a trade or business.  Sec. 274(a)(1)(A) and (2)(A).                         
               The substantiation required for meal and entertainment                 
          expenses should include the nature (including the amount, time,             
          and place of the meal or entertainment), the business purpose of            
          the claimed business expense, and the business relationship to              





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