- 60 - Even under a subjective methodology, the evidence in the record is simply insufficient to permit a deduction. Assuming arguendo that a once-wear policy would render clothing unsuitable for personal wear in petitioners’ particular situation, Mr. Deihl’s generalized testimony does little to show that each of the claimed charges was in fact for the purchase of such a once- wear item. As respondent notes, among the Neiman Marcus charges is one showing two turtlenecks at $165 each. We are unconvinced that Mr. Deihl’s testimony is not overly broad and exaggerated, and we are left with no reasonable basis on which to make any estimate as to legitimately once-wear garments.12 I. Equipment and Furnishings The credit card statements submitted in conjunction with expenditures claimed under training, meetings, and/or conventions and under promotion also reflect purchases at various establishments labeled with descriptions indicating some form of equipment, furnishings, or similar items. For instance, petitioners seek to deduct charges to Circuit City and Best Buy characterized as “ELECTRONICS/APPLIANCES”. Petitioners’ 12 As a final observation, we note that an additional basis for disallowance rests in the fact that Mr. Deihl indicated that garments were given to charity, thereby raising the possibility of a double deduction absent evidence that these amounts were not already incorporated in the charitable contribution deductions claimed by the various related entities.Page: Previous 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 Next
Last modified: May 25, 2011