Michael P. and Pamela J. Hopkins - Page 12

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          for 1999 Mr. Hopkins’s S Corporation is entitled under section              
          162(a) to deduct (1) as advertising expenses an unspecified                 
          reasonable amount of Mr. Hopkins’s S Corporation’s expenditures             
          of $16,501 in excess of the amount of such expenditures (i.e.,              
          $3,772) that respondent allowed that S Corporation to deduct15              
          and (2) as promotional expenses an unspecified reasonable amount            
          of Mr. Hopkins’s S Corporation’s expenditures of $39,557.16  We             
          shall address hereinafter the additional deductions for 1999 to             
          which petitioners claim Mr. Hopkins’s S Corporation is entitled,            
          and not the correlative effect in petitioners’ Schedule E that              

               15With respect to Mr. Hopkins’s S Corporation’s expenditures           
          of $16,501, respondent allowed advertising expense deductions for           
          (1) $3,490 of unidentified automobile racing expenditures and               
          (2) $282 of advertising (hats) expenditures (or a total of                  
          $3,772). Petitioners presented no evidence and make no argument             
          with respect to, and do not otherwise appear to challenge, $9,609           
          of the disallowed amount of Mr. Hopkins’s S Corporation’s expen-            
          ditures of $16,501, which the parties stipulated was for loan               
          payments with respect to petitioners’ motor home.  See supra note           
          8.  We conclude that petitioners have abandoned contesting that             
          disallowed amount.  We further conclude that petitioners are                
          contesting only $3,130 of Mr. Hopkins’s S Corporation’s expendi-            
          tures of $16,501.  For convenience, we shall sometimes refer to             
          such contested amount as Mr. Hopkins’s S Corporation’s claimed              
          advertising expense deduction of $3,130.                                    
               16With respect to Mr. Hopkins’s S Corporation’s expenditures           
          of $39,557, petitioners presented no evidence and make no argu-             
          ment with respect to, and do not otherwise appear to challenge,             
          $557 of such expenditures, which respondent disallowed as, and              
          which the parties stipulated was for, country club dues.  See               
          supra note 9.  We conclude that petitioners have abandoned                  
          contesting the disallowed country club dues payments of $557.  We           
          further conclude that petitioners are contesting only $39,000 of            
          Mr. Hopkins’s S Corporation’s expenditures of $39,557.  For                 
          convenience, we shall sometimes refer to such contested amount as           
          Mr. Hopkins’s S Corporation’s claimed promotional expense deduc-            
          tion of $39,000.                                                            





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