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SCC claimed that the expenses for advertising were
deductible as ordinary and necessary business expenses.
Respondent determined that SCC was not entitled to deduct these
expenses as shown on the financial statements and the
accountants’ compilations provided by SCC and adjusted these
expenses in determining SCC’s tax liabilities for the years at
issue. SCC’s canceled checks supported many of these promotional
expenses. In addition, members of SCC’s sponsored teams
testified credibly to substantiate the expenses. Accordingly, we
conclude the amounts of the following advertising or promotional
expenses for the years 1991, 1992, 1993, and 1994 were ordinary
and necessary expenses of SCC:
1991
Date Expense Amount
1/2 Letterman Sports $50.00
1/2 Letterman Sports 644.80
2/2 A & B 42.38
2/4 Gladiators 74.00
2/27 Letterman Sports 186.00
2/27 SRO Softball 320.00
3/23 USA Wrestling 30.00
4/9 SRO Softball 615.00
4/10 SRO Softball 320.00
4/19 Letterman Sports 297.75
5/7 Dave’s Sports 73.62
5/8 Letterman Sports 50.00
5/15 Athlete’s Foot 37.09
5/17 USA Wrestling 10.00
5/17 USA Wrestling 20.00
6/5 Letterman Sports 95.40
6/13 Letterman Sports 271.75
6/19 Letterman Sports 50.00
8/13 Letterman Sports 48.00
9/12 SRO Softball 225.00
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