Joseph A. and Sari F. Deihl - Page 42

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          to regulations, this rule applies to “membership in any club                
          organized for business, pleasure, recreation, or other social               
          purpose”, which definition includes, but is not limited to,                 
          “country clubs, golf and athletic clubs, airline clubs, hotel               
          clubs, and clubs operated to provide meals under circumstances              
          generally considered to be conducive to business discussion.”               
          Sec. 1.274-2(a)(2)(iii)(a), Income Tax Regs.  Membership dues and           
          related charges paid to the Arizona Club, Gardiner’s Resort, and            
          Gainey Ranch are therefore nondeductible.                                   
               With respect to other amounts paid to clubs, legislative               
          history accompanying passage of section 274(a)(3) in 1993, after            
          stressing the blanket disallowance for club dues, states:                   
          “Specific business expenses (e.g., meals) incurred at a club are            
          deductible only to the extent they otherwise satisfy the                    
          standards for deductibility.”  H. Conf. Rept. 103-213, at 583               
          (1993), 1993-3 C.B. 393, 461.  Here, the record fails to show               
          that the payments made to the Arizona Club, Gardiner’s Resort,              
          and Gainey Ranch do so.  Petitioners claimed expenses under the             
          characterization of training, meetings, and/or conventions but              
          have offered insufficient evidence to connect any of the                    
          expenditures to a particular business outing or function.                   
          Generalized testimony and unsupported estimates regarding                   
          business use constrain us to rely on the invoices themselves.               
          These invoices indicate meal and entertainment expenditures                 






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