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More than $11,000 was reported as paid to Aramark Sports &
Entertainment in June of 1998, but no invoices or bills are
contained in the record. The sole testimony regarding these
amounts was the following statement by Mrs. Deihl: “I believe
those are entertainers that we hired because we used to for the
conventions and different events that went on we would hire
dancers and magicians and all sort of entertainers.” Similarly,
Mrs. Deihl testified as to payments to Arizona Arts Chorale in
March of 1997 deducted by KareMor: “Arizona Arts Chorale I
believe is a local chorus or singing group”, which was hired to
“Entertain distributors” for business events. While the Court
has little doubt that petitioners did employ various entertainers
in conjunction with business functions, this generalized
testimony is insufficient to establish the deductibility of any
particular outlay for purposes of either section 162 or section
274.
A like problem exists with respect to payments to Affairs
Unlimited in the amount of $6,000 made in September of 1997 and
deducted by KareMor and in the amount of $11,372.56 made in
November of 1997 and deducted by Mayor. The sole explanation in
the record is: “They’re a staging company. They set up sets and
decor for parties.” The Court was not provided with evidence or
facts about the nature of any specific “parties” that would
support deductibility of these items.
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