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conduct of a business, the taxpayer must have had more than a
generalized expectation of deriving income or a specific business
benefit at some indefinite future time from those entertained.
Walliser v. Commissioner, supra at 441. Even if such expenses
are business related within the meaning of section 162, however,
they must be substantiated pursuant to section 274(d) and the
regulations thereunder. Sec. 1.274-1, Income Tax Regs.
Beck's Liquors did not comply with the detailed
substantiation requirements of section 274 and the regulations
thereunder. Beck's Liquors deducted meal expenses because some
topic related to the liquor store was always discussed. Mr. Beck
testified that, during the meals, he was entertaining clients or
discussing business with an employee or supplier. A taxpayer's
general testimony that business was always discussed during the
entertainment is not sufficient to establish a business purpose.
The fact that there was a general discussion of the liquor store
does not establish a business purpose directly related to the
business of Beck's Liquors. Rutz v. Commissioner, 66 T.C. 879,
884 (1976); Leon v. Commissioner, T.C. Memo. 1978-367.
c. Cost of Tickets To Various Sporting Events
Beck's Liquors purchased tickets to various sporting events
for promotional purposes and deducted the cost as an
entertainment expense. Respondent allowed all but $200 of the
cost of the tickets as a deductible expense. Respondent did not
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