Churchill Downs, Inc. v. Commissioner

115 T.C. 279 (2000)

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Churchill Downs, Inc. v. Commissioner

United States Tax Court
115 T.C. 279 (2000)

Facts

Churchill Downs, Inc. (plaintiff) owned and operated a horse-racing facility in Louisville, Kentucky. Churchill Downs sponsored the Kentucky Derby and, on a rotating basis, the Breeders’ Cup. Churchill Downs also hosted and paid for a number of promotional events surrounding the Kentucky Derby and the Breeders’ Cup, including cocktail parties, dinners, brunches, and a hospitality tent for the press. The events were primarily attended by horsemen, sponsors, racing officials, VIPs, media personnel, and Churchill Downs employees. Churchill Downs was required to put on some of the Breeders’ Cup events by contract. On its 1994 and 1995 tax returns, Churchill Downs claimed deductions for the food and entertainment expenses it incurred hosting the Kentucky Derby and Breeders’ Cup events. The commissioner of internal revenue (defendant) determined deficiencies on the grounds that the deductions were limited by Internal Revenue Code § 274(n)(1), and Churchill Downs sought review in the tax court.

Rule of Law

Issue

Holding and Reasoning (Laro, J.)

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