Randall and Lynn Bishop - Page 12




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              E.  Meals and Entertainment                                             
              Petitioners claim a deduction under section 162(a) for meals            
         and entertainment in the amount of $8,719 ($17,438 before taking             
         into account the 50-percent reduction in the deductibility of                
         such expenses provided for by section 274(n)(1)).3                           
              The substantiation requirements of section 274(d) apply to              
         entertainment activities.  Section 274(a)(1)(A) places additional            
         restrictions on the deduction of expenses with respect to                    
         entertainment activities.  Section 1.274-5T, Temporary Income Tax            
         Regs., 50 Fed. Reg. 46014 (Nov. 6, 1985), contains the                       
         substantiation requirements for deductible, business-related                 
         entertainment, including meals with customers or clients.4  The              
         applicable requirements, contained in paragraph (b) of section               
         1.274-5T, Temporary Income Tax Regs. (substantiation of amount,              
         time, place, business purpose, and business relationship), are               
         satisfied by the Exhibit B1 and B2 formats.                                  
              Petitioners’ substantiation schedule separately lists                   
         (1) expenditures totaling $13,051.56, for restaurant meals with              
         clients, potential clients, and persons referring potential                  
         clients (restaurant meal expenses), and (2) expenditures totaling            

               3  The allegedly deductible expenditures are contained in              
          Exhibits B1 and B2 accompanying petitioners’ reply brief.                   
               4  Mistakenly, petitioners cite sec. 1.274-2(f)(2)(i),                 
          Income Tax Regs., which provides a quiet-business-meals exception           
          but which applies to “[b]usiness meals and similar expenditures             
          paid or incurred before January 1, 1987".                                   





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