Ragnhild A. Westby - Page 72

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          deductible and testified that other items were misclassified but,           
          nevertheless, were deductible business expenses.                            
               (f) For 1989, petitioner presented documentation of the                
          following expenditures that were listed on Exhibit 40-R in the              
          following categories:                                                       
          Category                      Line Nos.                Amount               
          Client gifts             148-162                       $465.13              
          Employee & client                                                           
          gifts & entertainment    950-1076                 3,365.06                  
          Client gifts             1469-1481                     178.62               
          Client entertainment     1485-1529                     747.61               
          American Express             11796-1835           1,118.95                  
                                                                                     
               1Some of these items, which do not appear to be meal or                
          entertainment expenses, have been conceded by respondent.  The              
          amount shown has been reduced by the conceded amounts.                      
               (g) For 1990, petitioner presented documentation of the                
          following expenditures that were listed on Exhibit 41-R in the              
          following categories:                                                       
          Category                      Line Nos.                Amount               
          Business promotion            151-166             $1,252.94                 
          Client gifts                  193-206             534.09                    
          Employee gifts                877-883             543.37                    
          Client entertainment          887-964             1,909.23                  
          Business promotion            1303-1306                429.31               
          Client entertainment          1439-1478           1,074.75                  
          Client gifts                  1579-1593                484.17               
               After reviewing petitioner’s documentation and testimony, we           
          have no doubt that a properly conducted audit of petitioner’s               
          meals and entertainment and business promotion records could have           
          resulted in a reasonable dispute regarding whether the                      
          requirements of section 162 have been satisfied with respect to             





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