- 12 - 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.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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