Churchill Downs, Inc. v. Comm'r of Internal Revenue

2 Citing cases

  1. Becnel v. Comm'r

    T.C. Memo. 2018-120 (U.S.T.C. Aug. 2, 2018)

    Id. Becnel argues that he's more like the dressmaker and cites in support Churchill Downs, Inc. v. Commissioner, 307 F.3d 423 (6th Cir. 2002), aff'g 115 T.C. 279 (2000). In Churchill Downs, 307 F.3d at 424-25, the company behind the Kentucky Derby deducted 100% of its expenses for promotional parties, brunches, and dinners; the Commissioner disallowed 50% of the deductions as entertainment expenses limited under section 274(n).

  2. Henao v. Comm'r

    T.C. Summary Opinion 2016-7 (U.S.T.C. Feb. 8, 2016)

    There is no evidence that petitioner made the cruise tickets available to the general public or a cross-section thereof, as opposed to persons he selected. See 274(e)(7); Churchill Downs, Inc. v. Commissioner, 115 T.C. 279 (2000), aff'd, 307 F.3d 423 (6th Cir. 2002); sec. 1.274-2(f)(2)(viii), Income Tax Regs. Petitioner also contends that $1,390.02 of his claimed employee business expense deduction for 2010 that respondent disallowed constitutes expenditures for meals (retention meals) and gift certificates (retention gift certificates) that he provided to timeshare purchasers as a "goodwill" gesture to encourage them not to exercise their cancellation rights.