- 12 - testimonial evidence to substantiate any amount in excess of what respondent conceded. For the meals and entertainment expenses, petitioner’s “substantiation” consists merely of receipts and a smattering of testimony regarding these meal items, which, at best, establish that money was spent. Petitioner failed to reveal the business purpose of each meal and/or the business relationship of the person entertained, as is required by section 274(d). In addition, some of the receipts do not reveal the time and place of the meetings, while others pertained to meetings that occurred during a taxable year not before the Court. Several receipts reflect large expenditures for food and drink for many people. Petitioner explained that Stewart had several rules (such as not being late for a bus) which, if violated, required the “guilty” person to pick up the restaurant tab for the entire band. These may or may not be Stewart’s rules, but we know of no authority to support a finding that such activities constitute ordinary and necessary expenditures. Petitioner claimed deductions for depreciation expense in the amount of $1,673 and professional supplies in the amount of $17,329. To support these deductions, petitioner submitted receipts and invoices totaling $17,132. Respondent concedes that petitioner spent $17,132 on musical equipment and supplies during 1991, of which $825 is currently deductible and $16,307 is nondeductible, but depreciable. Despite these concessions,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
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