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travel expenses running errands for AIM. We disagree that AIM
may deduct Mrs. Boler’s travel expenses. A taxpayer may not
deduct travel expenses unless the taxpayer substantiates by
adequate records or sufficient evidence corroborating the
taxpayer's own statement, the amount, time and place, and
business purpose of the expense. Sec. 274(d)(4). Petitioners
offered no evidence of the amount, time, place, and business
purpose of Mrs. Boler’s travel expenses on behalf of AIM. Thus,
petitioners have not complied with section 274(d)(4) as to the
claimed deduction in 1994 based on Mrs. Boler’s travel expenses.7
H. Reimbursements Based on Undescribed Journal Entries
Petitioners contend that AIM may deduct the following
expenses coded in AIM’s journals: $1,254 as GJ1 18308, $600 as
GJ1 00172, and $480 as GJ1 001740 (the coded expenses at issue),
and reimbursed to petitioner in 1995. Petitioners contend that
Scott incurred, and petitioner paid the coded expenses at issue
as, travel expenses relating to a job that Scott did for AIM in
Pine Hill, Alabama. However, petitioners offered no evidence to
support that contention. Petitioners offered no evidence of the
time, place, or business purpose of the alleged travel expenses.
7 Respondent did not determine and does not contend that
the $4,200 amount is a constructive dividend to petitioner.
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