- 12 - for a gift, i.e., the cost of the gift to the taxpayer; (2) the time of each such expenditure, i.e., the date of the gift; (3) the description of each such expenditure, i.e., a description of the gift; (4) the business purpose of each such expenditure, i.e., the business reason for the gift or nature of the business benefit derived or expected to be derived as a result of the gift; and (5) the business relationship of each such expenditure, i.e., the occupation or other information relating to the recipi- ent of the gift, including name, title, or other designation, sufficient to establish business relationship to the taxpayer. Sec. 1.274-5T(b)(5), Temporary Income Tax Regs., 50 Fed. Reg. 46016 (Nov. 6, 1985). Petitioner testified that he did not use the $1,600 McKendree driving allowance to pay for vehicle expenses, as required by McKendree’s reimbursement policy. Instead, according to petitioner’s testimony, he used that driving allowance to pay for the claimed gifts totaling $1,600 to customers and prospec- tive customers of McKendree. Petitioner testified: I would basically purchase very inexpensive gifts generally under $20, give it either to potential cli- ents or give it to present clients just as a way of greasing the skids. So all the gifts I gave I kept track of. I know what days I gave it on. Sometimes I don’t have exactly who I gave it to, but other times I did. I wasn’t exact about writing down the name of the person. All that was done in that year. It was fully expensed, and I basically kept track of that.Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 NextLast modified: November 10, 2007