Danielle L. Clark-Hernandez - Page 13




                                       - 12 -                                         

          expenses for the receipts as noted above.  It is well settled,              
          however, that we are not required to accept a taxpayer’s self-              
          serving testimony in the absence of corroborating evidence.  See            
          Niedringhaus v. Commissioner, 99 T.C. 202, 212 (1992).                      
               Respondent is sustained on this issue.                                 
               2.  Meals and Entertainment                                            
               Petitioner deducted meals and entertainment expenses in                
          1991, 1992, and 1993, respectively, of $8,964, $6,677, and                  
          $7,252.  Respondent allowed $1,000 for each respective year.                
               The record reflects that petitioner deducted the costs of              
          personal meals she had with her fianc� under the guise of                   
          “management meetings”.  Petitioner testified that she had                   
          barbecues or cookouts for suppliers, vendors, and employees.  She           
          also cooked meals at home and served them to employees at the               
          work site.  Petitioner had receipts reflecting a birthday dinner            
          for her fianc� where one other employee may have attended; thus,            
          according to petitioner, it qualified as a business-related meal.           
          She had multiple receipts for purchases made at local grocery               
          stores and fast food restaurants when she was “out of the area”.            
               Entertainment included baseball tickets to Brewers baseball            
          games for employees, theater tickets, and tickets to the                    
          Milwaukee Zoo for her Japanese acquaintances.  However, similar             
          to the meals expenses, petitioner has failed to follow the strict           
          substantiation rules of section 274(d).                                     






Page:  Previous  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  21  22  Next

Last modified: May 25, 2011