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A KareMor December 31, 1998, ledger entry for $25,840 to the
Heart Association, likewise deducted under promotion, was allowed
to the extent of $23,440, and the balance of $2,400 was denied.
The record contains a receipt from the American Heart Association
issued in connection with the 1998 Heart Ball acknowledging cash
received of $25,000, less a value of $1,560 for 10 seats at the
Heart Ball (including dinner, entertainment, and favors), for a
charitable contribution of $23,440. No further testimony was
offered.
Petitioners also originally sought deduction of a $5,000
Republican Party contribution for KareMor in 1998 under training,
meetings, and/or conventions. A $5,000 amount under this heading
was conceded by petitioners in the stipulation of facts without
indication of the specific charge or charges involved.
Petitioners did not present any argument on brief relating to
this expenditure. The only other expense of $5,000 disallowed
under this category for KareMor in 1998 was one of the payments
to Aramark Sports & Entertainment, and petitioners on brief
requested a finding of fact supporting deduction of outlays to
this entity.
Although petitioners have never articulated any particular
legal theory bearing on the deductibility of the above payments,
we make the following general observations. Section 170(a)
provides for deduction of charitable contributions made to or for
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