- 20 - offered little evidence that the landscaping improvements were appropriate or necessary to the maintenance and development of Holland America’s business. See Commissioner v. Heininger, 320 U.S. at 471. Drive-by customers accounted for a very small percentage of Holland America’s sales, and there is no evidence in the record demonstrating that sales to Holland America’s regular customers increased in any material way as a result of the improvements. At trial, Martin Meskers, a flower grower from Oregon who has purchased bulbs from Holland America since its incorporation and spends about $500,000 per year at Holland America, testified that the new landscaping was nice and gave a good first impression. Mr. Meskers admitted, however, that he still would spend the same amount per year even if the landscaping was not as nice because Holland America carries the product he needs. We hold that petitioners have not proven that the landscaping expenses were ordinary and necessary business expenses deductible by Holland America under section 162. C. Groceries (“Supplies” Expense) In November 1993, Holland America reimbursed Mr. and Mrs. Dobbe in the amount of $34,246 for all groceries purchased for every meal prepared or eaten by the Dobbe family at their home from January 1989 through September 1993. Holland America deducted the entire reimbursement as a “supplies” expense on itsPage: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
Last modified: May 25, 2011