- 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.
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