- 71 -
retained by petitioner as part of her business records were no
longer legible.
(d) For 1987, petitioner presented documentation of the
following expenditures that were listed on Exhibit 38-R in the
following categories:20
Category Line Nos. Amount
Bachman’s (bus. gifts) 64-70 $118.96
Client entertainment 485-521 971.63
Credit cards 1171, 1173, 1175, 1,496.72
1181-1189, 1192,
1197-1232
(e) For 1988, petitioner presented documentation of the
following expenditures that were listed on Exhibit 39-R in the
following categories:
Category Line Nos. Amount
Client & employee gifts
& entertainment 1183-1297 $8,126.48
Client gifts 1593-1608 139.46
Employee benefits 1612-1637 195.49
Office party 1641-1643 131.66
Client entertainment 1677-1740 935.18
Of the expense items listed on lines 1183-1297, respondent
conceded that $2,266.55 was deductible, and the nature of the
expenses indicates that they were not entertainment expenses.
During trial, petitioner conceded that some of the items were not
20Petitioner “conceded” several of the smaller expense
items; i.e., she did not offer any additional evidence regarding
them, because she was interested in getting to the “large items”.
She did not concede that the items were not deductible, however,
and she did document the date and amount of the expense and the
identity of the payee as reflected on Exhibits 38-R through 41-R.
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