Ragnhild A. Westby - Page 73

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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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