- 10 -
time and place the expense was incurred, (3) the business purpose
of the expense, and (4) the business relationship to the taxpayer
of each expense incurred. Sec. 1.274-5T(b)(4), Temporary Income
Tax Regs., 50 Fed. Reg. 46015 (Nov. 6, 1985).
Petitioners did not provide any records outside of receipts
to substantiate the business purpose of these meals. Casual
conversation about business matters among business associates or
fellow employees does not satisfy the business purpose
requirement of section 274(d). Sec. 1.274-2(c), Income Tax Regs.
Therefore, no deduction for meals is allowed.
However, we find that petitioners are entitled to a
deduction for the food purchased for the reception after one
recital. Petitioners provided an announcement for the recital
and receipts for food purchases. Petitioners are entitled to a
deduction of $89.
Performance Clothing
Mrs. Popov was required to wear certain types of clothing
and shoes for the performances. Petitioners presented pictures
and receipts for skirts, dresses, pants, blouses, sequined
blouses, and shoes that were purchased in 1993. For the Los
Angeles Chamber Orchestra and the Long Beach Symphony, Mrs. Popov
was required to wear black. Mrs. Popov testified that the type
of music to be performed would dictate what she was to wear. She
also testified that she is not fond of the color black.
Petitioners claimed a clothing expense of $1,296.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011