Ralph Louis Vitale, Jr. - Page 14




                                        -14-                                          
          connection with his travels to Nevada.  For the years in issue,             
          the record contains documentary evidence of petitioner's travel             
          and meal expenses; i.e., airline tickets and travel schedules,              
          and hotel, restaurant, rental car, and credit card receipts.                
               With respect to petitioner's interviews, he characterized              
          the amounts he paid to the prostitutes as business related                  
          depending upon whether information gleaned from the interviews              
          was used in his books.  Petitioner has personal credit card                 
          receipts for 1994 supporting the expenditures he incurred to                
          interview prostitutes away from the brothels.  Petitioner does              
          not have receipts of his cash expenditures in 1993 for the                  
          interviews that took place at the brothels.  Nor does petitioner            
          have records supporting his deductions for advertising, commis-             
          sions and fees, office expenses, supplies, utilities, or those              
          expenses comprising "other expenses" for 1994 (with the exception           
          of the interviews).                                                         
               Around the time of the parties' preparation of a stipulation           
          of facts, petitioner prepared a five-page reconstruction of his             
          expenditures, using information reflected on airline tickets and            
          itineraries, hotel and rental car bills, credit card receipts,              
          and petitioner's own memory.  This included summary statements              
          for 1993 and 1994, a flight log, and a log of his interviews.               
               In the notice of deficiency, respondent disallowed under               
          sections 162 and 183 all of the expenses claimed on petitioner's            






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