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organizations were deserving. We hold that section 274(b) limits
to $25 the deduction available for each of the 36 gift
certificates claimed to represent a deductible expenditure.
2. Gift Nut Baskets
As regards the gift nut baskets, we observe as a preliminary
matter that respondent’s determinations include adjustments
reducing the deductions claimed with respect to both the baskets
given to nonemployees and those given to employees of R&J. The
pleadings filed by petitioners also dispute disallowed amounts
related to both types of recipient. On brief, however,
petitioners address only their entitlement to increased
deductions for sums expended to purchase the baskets given to
those stipulated as employees. We thus assume, and deem,
petitioners to have conceded that they are allowed to deduct only
$25 for each basket given to those designated by stipulation as
nonemployees. See Rules 142(a), 149(b). In this connection, we
also note that respondent has pointed out on brief that conflicts
within certain documents in the record may indicate that several
recipients of baskets not identified as employees may in fact
have held that status. However, because petitioners do not so
argue, and because any such error would be in respondent’s favor
based on our resolution below, we accept the parties’ numerical
stipulations in this regard.
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