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fide business expenses which would be deductible under section
162. See Harwood v. Commissioner, supra at 258; see also
Schaefer v. Commissioner, supra. Toraya has the burden of
establishing that the payments to Junichi and Joan served a
business purpose and were reasonable in amount.
The record shows that during the years in issue it was
Toraya's practice to give money to the restaurants' managers
(Motomi in the case of the Post Street restaurant and Junichi in
the case of the Berkeley restaurant) to purchase food and
supplies for the restaurants. At trial, petitioners introduced
checks payable to Joan in 1988 and 1989 totaling $24,300 and
$7,100, respectively. Petitioners introduced additional checks
payable to cash in 1989 and endorsed by Junichi totaling $4,000.
Nakamura testified that Toraya gave these checks in order for
Junichi to make cash purchases of food for the Berkeley
restaurant. Five checks written to Joan in 1988, totaling
$8,000, carried a notation indicating "purchases" or a derivation
thereof on the memo line. One check written to Joan in 1989,
totaling $1,100, carried the notation "Payroll" on the memo line.
The other checks written to Joan had no notation on the memo
line. The checks written to cash and endorsed by Junichi all had
notations on the memo lines indicating that the checks were for
produce. Neither Junichi nor Joan testified at trial.
We are persuaded that Junichi purchased food for the
Berkeley restaurant. For 1988, petitioners submitted checks
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