Ronald and Sue M. Leschke - Page 4




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          certificates as an “Advertising” expense on its 1993 U.S. Income            
          Tax Return for an S Corporation, Form 1120S.  (Although the                 
          record reflects corporate recipients for 37 gift certificates,              
          one certificate was apparently omitted by R&J in calculating the            
          claimed deduction.)  Upon subsequent examination, respondent                
          allowed a deduction of $25 per gift certificate, for a total of             
          $900, and disallowed the balance.                                           
          Gift Nut Baskets                                                            
               During each of the years 1993 and 1994, R&J gave gift nut              
          baskets to 166 nonemployees and 44 employees as promotional                 
          Christmas gifts.  The 210 baskets for each year were purchased at           
          a cost of $61 apiece, for a total of $12,810.  With respect to              
          the baskets given in 1993, R&J paid $7,500 of the purchase price            
          in 1993 and deducted such amount in that year as an                         
          “Administrative” expense.  The remaining portion of the price,              
          $5,310, was paid and deducted in 1994, designated as an                     
          “Advertising” expense.  With respect to the baskets given in                
          1994, the full $12,810 was both paid and deducted as an                     
          “Administrative” expense in that year.                                      
               Pursuant to the above-mentioned examination, respondent                
          allowed for the 1993 year a deduction of $25 per gift for only              
          the 166 baskets given to nonemployees.  For 1994, a deduction of            
          $25 per gift was allowed for all 210 baskets.  Any additional               
          amounts claimed were disallowed.                                            






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