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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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