- 9 - 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 toPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011