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No food or entertainment was offered to the public either on the
premises or inside the building during those years.
B. 1992 and 1993
Because of the many difficulties petitioners encountered in
financing and completing the renovation of the 5401-9 S. Broadway
property, petitioners were forced to alter their original plans.
They put their plans for the 5-4 Ballroom on hold and decided to
open a “Bluesroom” on part of the building’s first floor.
Beginning in August 1992, petitioners permitted a few
performances and fundraising events to be held on the 5401-9 S.
Broadway property. As of that date, however, and continuing
through 1993, petitioners did not yet have any functioning
restaurant or entertainment facility that petitioners operated
for profit. Any events held on the 5401-9 S. Broadway property
during 1992 and 1993 were organized by volunteers who collected
admission fees and used the admission fees to offset the cost of
the event and to pay the performer. Petitioners did not retain
any of the receipts from the events and charged no rent for the
use of the property. Petitioners viewed these events as
opportunities to promote the Bluesroom and to solicit investors
who might be willing to invest funds to complete the renovation
of the property.
During 1992 and 1993, petitioners did not maintain any
general ledger, cash receipts and disbursements journals, or
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