Joseph A. and Sari F. Deihl - Page 56

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               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:                     







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