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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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