Karan M. Hintze - Page 18

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          (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.                                    

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