- 3 - Petitioner claimed meal and entertainment expenses of $1,720 in 1996 and $1,274 in 1997. Subtracting 50 percent of these expenses pursuant to the section 274(n) limitation, he claimed deductions of $860 and $637, respectively. Separately from these deductions, petitioner also claimed deductions for “business promotion” in the amounts of $2,544 and $2,120. In the statutory notice of deficiency, respondent disallowed half of each of the business promotion deductions. Generally, expenses which are ordinary and necessary in carrying on a trade or business are deductible. Sec. 162(a). However, subject to exceptions not applicable here, a deduction for any expense related to food, beverages, entertainment, amusement, or recreation is limited to 50 percent of the amount of the expense. Sec. 274(n). “Entertainment” includes entertainment, amusement, or recreational activities at golf and country clubs. Sec. 1.274-2(b)(1)(i), Income Tax Regs. Respondent argues that the business promotion deductions are subject to the 50-percent limitation because they are for meal and entertainment expenses; namely, restaurant and golf-related expenses. A summary prepared by petitioner’s representative during the audit of petitioner’s return lists the amounts constituting the total deduction claimed in 1996. The majority of the expenses were in fact from restaurants and a country club. The remaining expenses are of an unknown nature; petitioner didPage: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011