Joseph A. and Sari F. Deihl - Page 21

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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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