- 42 - 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 expendituresPage: Previous 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 Next
Last modified: May 25, 2011