- 21 - parties, from 1993 to 1999. Thus, the Court has a visual representation of petitioners’ operations. There is likewise no shortage of generalized verbal descriptions regarding how petitioners ran their operations, motivated distributors, gave away prizes, created a lifestyle to envy, and so on. The generalized summary videotape would therefore add nothing material to the evidence before the Court. The Court shall exclude the videotape on grounds of relevancy or cumulation and need not reach the additional bases for exclusion argued by respondent. II. S Corporation Expenditure Deductions The expenditures of Mayor and KareMor at issue in this proceeding were categorized, first in general ledgers and then correspondingly in relevant tax returns, notices of deficiency, stipulations, and briefs, as pertaining to (1) capitalized business improvements; (2) landscaping; (3) security; (4) training, meetings, and/or conventions; (5) promotion; (6) suspense; (7) marketing; or (8) meals and entertainment. As alluded to previously and as will be further elucidated infra in text, some of these classifications are ambiguous at best and do not lend themselves to analysis of pertinent issues. Accordingly, for purposes of discussion herein, the Court will employ the following groupings: (1) Amortization of residence improvements; (2) landscaping; (3) security; (4) clubs; (5)Page: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Next
Last modified: May 25, 2011