- 4 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011