Timothy Dean Strong - Page 28

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          groceries, for 1991-94 by issuing checks from account No.                   
          893315300.                                                                  
               There are seven general categories of additional disputed              
          expenses that were paid out of account No. 893315300 which we               
          will discuss:  (1) Advertising or promotional expenses; (2)                 
          professional fees; (3) travel expenses; (4) automobile and truck            
          expenses; (5) office supplies and general supplies; (6) utility             
          expenses; and (7) miscellaneous expenses.                                   
                    1.  Advertising or Promotional Expenses                           
               Expenses for the promotion or sponsorship of activities not            
          directly related to a taxpayer’s business are deductible if the             
          taxpayer can establish a proximate relationship between the                 
          activity and the taxpayer’s business such that the sponsorship              
          was reasonably calculated to advertise the business.  Gill v.               
          Commissioner, T.C. Memo. 1994-92, affd. without published opinion           
          76 F.3d 378 (6th Cir. 1996).                                                
               SCC advertised its business primarily either through word of           
          mouth or by athletic sponsorships.  As part of the athletic                 
          sponsorships, SCC paid for the uniforms, logo design, hats, t-              
          shirts, sweat pants, coats, bags, and pants for all players on              
          its sponsored teams.  In addition, SCC made monetary donations              
          for high school wrestling organizations and would provide                   
          equipment and league/tournament fees for its sponsored athletic             
          teams.                                                                      






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