- 70 -
(b) for entertainment, amounts of $951 and $169, totaling
$1,120 for 1987; amounts of $2,093, $316, and $42, totaling
$2,451 for 1988; amounts of $472 and 522, totaling $994 for 1989;
and amounts of $1,844, $478, $269, and $1,516, totaling $4,107
for 1990 before application of the section 274(n) limitation.
Our review of the record reveals the following:
(a) Petitioner maintained voluminous records to document
her practice of entertaining, and purchasing gifts for, clients,
employees, referral sources, judges, and other members of the
legal community throughout the years at issue.
(b) In his notices of deficiency, respondent did not assert
section 274 as a ground for disallowing any of petitioner’s
deductions for business promotion/advertising or for meals and
entertainment. Respondent only asserted a section 162 standard
as the basis for his proposed disallowance of petitioner’s
deductions.
(c) Petitioner testified extensively at trial regarding the
identity of the person who was entertained or to whom a gift was
given, as well as the business purpose of many of the individual
items comprising her business promotion and meals and
entertainment expenses. The date and amount of the expenditures
were documented by invoices, canceled checks, credit card and
other receipts, and other records. In some cases, receipts
Page: Previous 60 61 62 63 64 65 66 67 68 69 70 71 72 73 74 75 76 77 78 79 NextLast modified: May 25, 2011