Joseph A. and Sari F. Deihl - Page 38

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          personal in nature.  Again, however, the record provides no guide           
          for any reasonable estimation under Cohan v. Commissioner, 39               
          F.2d at 543-544.  Therefore, given the state of the record7 and             
          petitioners’ lack of any explanation or further argument, the               
          Court is not in a position to conclude that respondent’s                    
          allocations, with the limited exception discussed above, are                
          other than generally reasonable and supported by the available              
          documents.                                                                  
               E.  Clubs                                                              
               One of the many subsets of expenditures deducted by                    
          petitioners under the category referred to as training, meetings,           
          and/or conventions is outlays to Arizona Club, to Gardiner’s                
          Resort on Camelback (also referred to as Gardiner’s Tennis                  
          Ranch), and to Gainey Ranch Golf Club.  Mr. Deihl testified that            
          the Arizona Club is a private social club, charging membership              
          fees, with restaurant, banquet, and catering facilities.  He                
          stated that petitioners used the Arizona Club for events such as            
          business luncheons and training meetings.  They also utilized the           
          catering services for outside parties at their home.                        
          Additionally, Mr. Deihl testified that the family made personal             
          use of the club for events including holiday functions and                  


               7 As an additional observation, we point out that at least             
          $1,800 deducted as a security expense is highly suspect in that             
          invoices show the amount was charged to provide band music and              
          three carolers at a Christmas party.                                        




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