Dartmouth Clubs, Inc. - Page 4




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          protested the proposed adjustments at an administrative review in           
          the Internal Revenue Service Office of Appeals (Appeals).                   
          Appeals returned the case to the revenue agent with instructions            
          to consider whether additional evidence that petitioner had                 
          presented at the administrative review provided the required                
          substantiation.                                                             
               The parties were not able to reach an agreement on the                 
          disputed items, and petitioner refused to agree to a statutory              
          extension of the time to assess tax.  Accordingly, on April 30,             
          1998, respondent mailed a notice of deficiency to petitioner.               
               In the notice, respondent determined deficiencies of                   
          $219,885 and $249,372, and accuracy-related penalties of $43,977            
          and $49,874, for petitioner's fiscal years 1994 and 1995,                   
          respectively.  The deficiencies were based on the disallowance of           
          deductions that petitioner claimed for casual labor, security               
          expenses, talent scouting expenses, music expenses, and                     
          management consulting fees.                                                 
               The notice of deficiency stated that the deductions for the            
          casual labor, security expenses, music expenses, and management             
          consulting fees were disallowed because petitioner did not                  
          provide substantiation, including invoices, matching canceled               
          checks, and Forms 1099, to support its claimed deductions.                  
          Respondent disallowed the deduction for the talent scouting                 
          expenses, because he determined that $104,000 of the amount                 






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