- 28 - 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.Page: Previous 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 Next
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