Henry C. Boler and Sherry M. Boler - Page 19




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          have records.  Thus, there is no need to estimate amounts under             
          Cohan.                                                                      
               We conclude that AIM may deduct $442 in 1994, $40 in 1995,             
          and $243 in 1996 for reimbursing petitioner for high school                 
          student labor expenses.  Those amounts are not constructive                 
          dividends to petitioner.                                                    
          E.   Golf Expenses                                                          
               AIM reimbursed petitioner for one-half of the expenses that            
          he incurred for golf in 1995 and 1996.  Petitioners contend that            
          AIM properly deducted AIM’s reimbursement to petitioner of golf             
          expenses of $236 for 1995 and $369 for 1996.  We disagree.                  
               Expenses of recreation and entertainment generally are                 
          nondeductible unless the taxpayer substantiates by adequate                 
          records, or by sufficient evidence corroborating his or her own             
          testimony:  (1) The amount of the expense; (2) the time and place           
          of the expense; (3) the business purpose of the expense; and (4)            
          the business relationship to the taxpayer of the persons                    
          entertained.  Sec. 274(d); sec. 1.274-5T(c)(3), Temporary Income            
          Tax Regs., 50 Fed. Reg. 46020 (Nov. 6, 1985).  Petitioners                  
          offered no evidence showing the place, the persons entertained,             
          the business purpose, or the business relationship to AIM of the            
          persons entertained.  Petitioners had no receipts.  Thus,                   
          petitioners have not met the requirements of section 274(d).                








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