Donald Victor Teschner - Page 12

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          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,                 

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