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children’s parties. He estimated that 80 to 85 percent of the
use was for business purposes and that 15 to 20 percent was for
pleasure or personal purposes.
Gardiner’s Resort, according to Mr. Deihl, is a private
tennis club where petitioners hosted certain smaller KareMor
meetings and events. It was Mr. Deihl’s testimony that all use
of Gardiner’s Resort was business rather than personal in nature.
As regards Gainey Ranch Golf Club, petitioners offered no mention
of this facility either at trial or on brief.
The record contains a number of invoices from each of these
clubs, and the descriptions of the charges thereon typically fall
into one of three general categories. The majority of the
descriptions include one or more words indicating food or drink
services (or tips in connection therewith), such as “Restaurant”,
“Dinner”, “Lunch”, “Food”, “Bev”, “Wine”, “Bar”, “Banquet”,
“Caterout”, “Tip”, etc. A smaller number of the descriptions
indicate equipment rentals, requested services, or labor in
connection with catered events. The remaining descriptions
principally comprise membership dues, finance charges, late fees,
or contributions to an employee Christmas fund.
As previously indicated, section 274 imposes limitations on
expenses relating to entertainment and associated facilities
beyond the general business purpose criterion of section 162.
Section 274(a) reads as follows:
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