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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)
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