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subject to a number of restrictions under section 274, and
petitioners have not shown otherwise. Even leaving aside
potentially applicable limitations under section 274(a) and (n),
it is enough to note that petitioners have in any event failed to
substantiate the expenditures pursuant to the exacting strictures
of section 274(d).
F. Entertainment
With respect to various other specific expenditures claimed
either under training, meetings, and/or conventions or under
promotion, petitioners offered testimony suggesting a connection
to activities or functions of a nature generally thought to
pertain to entertainment.8 Although petitioners deducted these
amounts as expenses for training, meetings, and/or conventions or
for promotion, they once again failed to offer any evidence that
would link the costs to any particular business function or event
or would show that the standards of section 274 should not apply.
8 As noted in our preliminary remarks, with respect to a
substantial portion of the items deducted as expenses for
training, meetings, and/or conventions or for promotion,
petitioners failed to address the specific expenditures at trial
or on brief. It is here in particular that the Court is
unwilling to rely on the self-serving characterizations used in
the general ledgers or mere credit card charge statements, which
standing alone do little to establish even a threshold business
purpose. We are equally unwilling to credit petitioners’ blanket
assertion that all charges to their “company” card were properly
business related. Such a position simply is not credible on the
record presented.
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