Mediaworks, Inc. - Page 7

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          club that was held for and attended by Roach and the races’ other           
          participants.                                                               
               Roach sailed in the beer can races with a total crew of 6 to           
          10 men and/or women, and none of these individuals was                      
          compensated for his or her services on board the Centurion during           
          these races.  Roach’s crew members for the beer can races varied            
          from week to week and consisted mainly of friends and whoever               
          else happened to show up at the yacht club for the races.  (One             
          of Roach’s regular crew members at these races was his personal             
          insurance agent.)  The commonality of all of Roach’s crew members           
          generally was that they enjoyed sailing.  Roach considered the              
          beer can races to be the perfect venue for entertaining clients             
          and prospective clients, and, on some occasions, he invited                 
          clients or prospective clients of petitioner on board the                   
          Centurion during the beer can races to allow them to experience             
          the joy of sailing.  Roach sometimes videotaped the happenings on           
          board the Centurion during the beer can races.                              
               During the subject years, Roach also sailed the Centurion              
          sometimes on weekends.  During each of those years, individuals             
          on board the Centurion took photographs, drank wine and beer, ate           
          cheese, and discussed personal matters.                                     
               On its Federal income tax returns for the subject years,               
          petitioner claimed the disputed deductions of $159,134 and                  
          $135,834, respectively, as to the Centurion.  These underlying              






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