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The Breeders’ Cup items and amounts in issue are:
Item Amounts in Issue
Breeders’ Cup party $116,000
Post-draw brunch 21,885
Press breakfast 7,500
Total 145,385
collectively referred to as Breeders’ Cup expenses.
The miscellaneous items and amounts in issue are:
Amounts in Issue
Item 1994 1995
Kentucky thoroughbred
owners’ & trainers’ dinner $2,310 $2,150
Cummings reception 1,630 -0-
Farewell party 1,000 -0-
Stakes day buffet -0- 13,132
Music theatre - derby
eve gala table -0- 2,500
U.S. Senate restaurant -0- 538
Dinner for twenty-five
at $19.36 per person -0- 484
Dinner for fifty-five
at $20.35 per person -0- 1,119
Louisville Chamber of
Commerce dinner -0- 500
Green Herb cocktail party -0- 1,196
Total 4,940 21,619
collectively referred to as miscellaneous expenses.
Discussion
Respondent concedes that all of the expenses at issue meet
the requirements for deductions as ordinary and necessary
business expenses of petitioner under section 162 for the years
in issue. However, respondent argues that these deduction are
limited by section 274.
Petitioners argue they are in the entertainment business,
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Last modified: May 25, 2011