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or use time in the suite, petitioner offered pricing incentives
to two corporations, Nabisco and Chicago Title. The two
companies agreed to the deal with petitioner. The sole expense
at issue in this case is a claimed deduction of $889.52 relating
to the activity.13
It appears that the expense in question was incurred at one
event, which was attended by petitioner and representatives of
Nabisco and Chicago Title. The evidence satisfies the Court that
the representatives of Nabisco and Chicago Title who attended the
game were not there for purposes of entertainment but were there
solely for their evaluation and consideration of how the facility
would be used to further the business interests of Nabisco and
Chicago Title, and petitioner was there to show the facility and
address whatever questions the corporate representatives may have
had. Petitioner paid for the food and beverages consumed at the
event, which amounted to $889.52.
While conceding that petitioner substantiated the expenses
and was entitled to claim the $889.52 paid for food and beverages
on Schedule C of his return as a business expense, respondent
contends that the expense was subject to the 50-percent
limitation of section 274(n). Petitioner argued that section
13 Petitioner claimed the $889.52 item as “Returns and
Allowances” on Schedule C for the trade or business activity
“Frexie”. At trial, petitioner clarified that the item was
mischaracterized and was properly a claimed business expense of
the Schedule C “Frexie” activity.
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