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each expense item and, if so, whether section 274 should operate
to preclude deductions for some of the items. We also have no
doubt, however, that petitioner had deductible meals and
entertainment expenses and purchased deductible business gifts
for clients, referral sources, and other professional people in
each of the years at issue. We also note that the documentation
presented by petitioner that was reviewed and summarized by
respondent in Exhibits 38-R through 41-R substantially exceeds
the deductions claimed by petitioner for advertising (business
promotion) and meals and entertainment in each of the years at
issue:
Year Total on return Total on exhibits
1987 $994 $2,587.31
1988 2,121 9,528.27
1989 1,308 5,875.37
1990 5,670 6,227.86
Recognizing the flaws in each party’s position, we conclude only
that petitioner paid advertising/business promotion and meals and
entertainment expenses in sufficient amounts to support the
deductions claimed in each of the years at issue.
s. Miscellaneous
For the years at issue, petitioner claimed deductions for
miscellaneous business expenses as follows:
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