Menard, Inc. - Page 88

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          sponsorship designation with respect to the Tony Stewart car and            
          less prominent logo placement on the Robbie Buhl car.  The                  
          $200,000 increase from the 1997 sponsorship fee may have been               
          partly attributable to Tony Stewart’s winning the IRL                       
          Championship in 1997.  Because the record does not indicate how             
          much Johns Manville paid to sponsor the Robbie Buhl car in 1998,            
          but TMI as a team shared the prestige of the 1997 IRL                       
          Championship win, we assume that the Robbie Buhl car sponsorship            
          fee increased at least half as much in proportion to the increase           
          in the Tony Stewart car sponsorship fee.  Accordingly, we                   
          attribute a sponsorship fee value of $1,583,333 to Johns                    
          Manville’s primary sponsorship of the Robbie Buhl car.69                    
               On the basis of the record, we conclude that, to the extent            
          Menards’s payment of the TMI expenses equaled the combined 1997             
          primary sponsorship fees paid by Glidden and Quaker State and the           
          combined 1998 primary sponsorship fees paid by Glidden and Johns            
          Manville, the TMI payments were reasonable in amount and                    
          deductible pursuant to section 162(a).  As a result, for TYE                
          1998, Menards may deduct as advertising expenses a prorated                 




               69We calculated the value as follows:  $200,000/1,800,000 =            
          .111111; .111111/2 = .055555; .055555 x 1,500,000 = $83,333;                
          1,500,000 + 83,333 = $1,583,333]                                            






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