- 56 - H. Clothing Among the expenditures claimed by petitioners under the categories of training, meetings, and/or conventions or of promotion were a number of charges incurred at establishments such a Capriccio’s Apparel, Battaglia Shop, Saba’s Western Wear, Bardelli Apparel, Cuzzens Forum, Danese Creations, Andrelani, and Neiman Marcus. The sole documentary evidence for the majority of these expenditures consists of credit card statements showing, if anything, a one- or two-word explanation such as “APPAREL/ACCESSORIES”. Only for purchases at Neiman Marcus do we have any appreciable number of invoices. Petitioners did not testify specifically as to any of these charges but did offer generalized statements about their purchases at these establishments. Mr. Deihl stated that Capriccio’s Apparel was a women’s fashion store, where Mrs. Deihl and other women of the family would purchase gowns to be worn on a one-time basis. He likewise explained that Battaglia Shop was a highend men’s and women’s clothing store where purchases “for business purposes” were made. His testimony about Saba’s, previously alluded to, admitted that both business and personal purchases were made at the western wear shop. Petitioners’ position on and rationale for the deductibility of such items was expounded in the following testimony:Page: Previous 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 Next
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