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OPINION
I. Deductions
Respondent contends that, under section 162(a), petitioner
is not entitled to the claimed employee business expense
deductions because petitioner has failed to substantiate that the
expenses (1) were incurred and (2) were ordinary and necessary
expenses of petitioner’s trade or business as a Crabtree
Dealerships business manager. See supra note 3. In addition,
respondent contends that petitioner is not entitled to these
deductions because of petitioner’s failure to meet the strict
record-keeping requirements of section 274(d).
Petitioner maintains that (1) he has satisfied the
requirements of section 162(a) as to all his claimed employee
business expense deductions, (2) he has satisfied the
requirements of section 274(d) as to his claimed meals expenses
deductions, and (3) section 274(d) does not apply to his claimed
automobile and other nonmeal business expense deductions.
Respondent apparently does not dispute petitioner’s contention
that section 274(d) does not apply to the claimed automobile and
other nonmeal business expense deductions. But see secs.
274(d)(1), and (4), and 280F(d)(4)(A)(i), and the regulations
thereunder.
We agree with respondent that petitioner has failed to
establish that he is entitled to any of these deductions.
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