Kenneth Andrew Baratelle - Page 18




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               Meals and Entertainment Expenses                                       
               On his 1994 Schedule C, petitioner claimed a deduction for             
          meals and entertainment in the amount of $2,435, calculated as              
          follows:                                                                    
                    Meals and entertainment            $4,871                         
                    Less: 50% limitation of sec. 274    (2,436)                       
                           Total deduction             $2,435                         
               Petitioner now contends that he is entitled to a deduction             
          for meals and entertainment of $1,770, calculated as follows:               
                    Meals and entertainment            $3,539                         
                    Less: 50% limitation of sec. 274    (1,769)                       
                           Total revised deduction     $1,770                         

               Of the revised meals and entertainment expenses claimed by             
          petitioner, respondent conceded that petitioner has substantiated           
          meals and entertainment expenses of $1,933.62 before the 50-                
          percent limitation of section 274(n) is applied.  Respondent                
          maintains that he has allowed a deduction for “substantially all            
          of the items for which petitioner has presented documentary                 
          evidence, except for the cost of golfing.”                                  
               We have reviewed the record, and we agree petitioner                   
          failed to substantiate the remainder of the items claimed.  The             
          remaining items fell into two categories–-meals for which                   
          petitioner presented no documentation ($1,328.89) and golf                  
          expenses as to which petitioner failed to substantiate all of the           
          elements required by section 274(d) ($323.60).  Section 274(d)              
          requires adequate documentation of a covered expense and its                





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