- 18 - (2) the date of entertainment; (3) the name, if any, address, or location of the entertainment; (4) the business reason for the entertainment or the nature of the business benefit derived or expected to be derived as a result of the entertainment and the nature of the business discussion or activity; and (5) the occupation or other information relating to the person or persons entertained, including the name, title, or other designation, sufficient to establish the business relationship to the taxpayer. See sec. 274(d); sec. 1.274-5T(b)(3), Temporary Income Tax Regs., 50 Fed. Reg. 46015 (Nov. 6, 1985). At trial, petitioner produced 29 receipts containing various notations which she contends substantiate business meal expenses in the amount of $1,600.13. Two of the receipts, totaling $500, represent expenses for food which petitioner provided at her seminars in Denmark. We addressed those expenses in our discussion of petitioner’s traveling expenses and shall not consider them here.12 With respect to the remainder of petitioner’s receipts, most of them contain only a notation identifying the individual or individuals entertained as “client” or “clients”. With respect to these expenses, petitioner has failed to provide adequate information relating to the person or persons entertained sufficient to establish the business 12 Petitioner was allowed a deduction for these expenses on the ground that they were not subject to sec. 274(d). They are included as items 4 and 5 in appendix A.Page: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Next
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