- 85 - 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]Page: Previous 75 76 77 78 79 80 81 82 83 84 85 86 87 88 89 90 91 92 93 94 Next
Last modified: May 25, 2011