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