- 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
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