- 38 - 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.Page: Previous 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 Next
Last modified: May 25, 2011