James M. and Karen K. Barton - Page 12

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          Meals and Entertainment Expenses                                            
               We turn now to petitioner’s claim for meals and                        
          entertainment expenses.  Petitioner claimed $2,422 of meals and             
          entertainment expenses on the basis of the master credit card               
          summary, which reflected $2,168 under the category “Restaurants”            
          and $232 under the category “Entertainment.”                                
               While the master credit card summary shows the name of the             
          restaurant (or payee), and the date and the amount spent, the               
          master credit card summary does not show the business purpose of            
          the activity or the name of the person entertained.  In                     
          attempting to substantiate the business purpose and the name of             
          the person entertained, petitioner prepared the reconstructed               
          entertainment list 3-1/2 years after the fact. Petitioner was               
          unable to testify as to whom he entertained in some instances.              
               We have the same concerns regarding the meals and                      
          entertainment expenses that we had with the automobile expenses.            
          The account was used for both personal and business purposes.               
          There was no breakdown on the master credit card statement                  
          between business and personal charges.  The credit card company             
          simply lumped all charges to restaurants under the “Restaurants”            
          category.  In addition, petitioner failed to explain which of the           
          expenses claimed were for business, not personal, purposes, and             
          petitioner failed to heed the Court’s advice to concede the                 
          personal charges.  Several charges appeared for various ski                 






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Last modified: May 25, 2011