- 9 -
We find that petitioners are entitled to a deduction of
$3,290 for use of the car (.28 x 11,750 miles). Petitioners’ log
and the calendar contain sufficient information to satisfy the
stringent substantiation requirements of section 274(d).
Meals and Entertainment
Mrs. Popov dined frequently with other musicians.
Occasionally, she would pick up the tab, and if someone else did,
Mrs. Popov would contribute money for her share. Mrs. Popov
entertained other musicians in order to make contacts, to obtain
engagements, and to enhance her reputation as a musician. She
stated that this was necessary since she was new to Los Angeles
and it was difficult getting into the music business. She
further contends that it was helpful since she made contacts
which helped increase her salary. In addition to making
contacts, Mrs. Popov dined with these people “to make more
friends and be social.” Petitioners submitted receipts from
restaurants, and on most of the receipts, the names of the people
present at the meal were listed.
Petitioners also submitted receipts for bulk food purchases.
Mrs. Popov testified that when she would give a recital, there
would be a reception afterwards for which she would provide
refreshments.
A taxpayer is required under section 274(d) to substantiate
entertainment expenses by adequate records to corroborate his or
her own testimony as to: (1) The amount of the expense, (2) the
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011