- 8 -
without identifying the customer. Therefore, in the instances
where it is somewhat clear which customer received the gift,
petitioner is entitled to a deduction. Overall, we conclude that
petitioner is entitled to a deduction of $1,035 for business
gifts.2
5. Meals and entertainment
Petitioner claimed a deduction of $5,594 for meals and
entertainment. Petitioner contended that he often purchased
snacks, lunches, and dinners for customers to attract sales. The
receipts for these items were allegedly destroyed in the flooding
from the rainstorm. In the calendar, petitioner occasionally
listed an amount next to a customer’s name on a specific date
along with “SNK” for snack or “lunch” or “dinner”. The majority
of the entries are just amounts next to “lunch” or “dinner” with
no indication that a customer was involved. From the best we
could discern from this rather unorganized and cryptic document,
petitioner incurred $926 in deductible meals expenses, which
amount is subject to the limitation provided by section 274(n).
We gave petitioner credit only where it was clear that a
specific purchase was for a customer. There were too many
repeated entries that said $22 for lunch and $30 for dinner.
2 Even if we allowed all gifts noted on the calendar, it is
still nearly $5,000 short of the amount claimed on petitioner’s
return. Petitioner did not offer any explanation as to what
other expenses this amount is attributable.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011