Randall and Lynn Bishop - Page 5




                                        - 5 -                                         
               We accept all of petitioners’ concessions.  After                      
          concessions, the deductions still in issue are as follows:                  
                         Depreciation             $13,232                             
                         Office expenses          8,762                               
                         Rental expenses          23,170                              
                         Meals and entertainment    8,719                             
                                     Discussion                                       
         I.  Deductions                                                               
              A.  Introduction                                                        
              We must determine petitioners’ entitlement to the deductions            
         still in issue for depreciation, office expenses, rental                     
         expenses, and meals and entertainment.  Because petitioners’                 
         principal challenge is substantiating their entitlement to those             
         deductions, we first set forth the pertinent parts of section                
         274(d), which sets forth requirements for substantiating certain             
         deductions:                                                                  
                   SEC. 274(d) Substantiation Required.–-No deduction                 
              or credit shall be allowed--                                            
                   (1) under section 162 or 212 for any traveling                     
                   expense (including meals and lodging while away                    
                   from home),                                                        
                   (2) for any item with respect to an activity                       
                   which is of a type generally considered to                         
                   constitute entertainment, amusement, or                            
                   recreation, or with respect to a facility used in                  
                   connection with such an activity,                                  
                        *  *  *  *  *  *  *                                           
                   (4) with respect to any listed property (as                        
                   defined in section 280F(d)(4)),                                    







Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  Next

Last modified: May 25, 2011