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“a high degree of probative value to elevate such statement and
evidence” to the level of credibility of a contemporaneous
record. Sec. 1.274-5T(c)(1), Temporary Income Tax Regs., 50 Fed.
Reg. 46017 (Nov. 6, 1985). Thus, no deduction for expenses under
section 274(d) may be allowed on the basis of any approximation
or the unsupported testimony of the taxpayer. See, e.g., Murata
v. Commissioner, T.C. Memo. 1996-321; Golden v. Commissioner,
T.C. Memo. 1993-602.
In this case, petitioner has attempted to substantiate his
expenditures through secondary and incomplete documentation. In
particular, petitioner offered credit card statements and a
reconstructed summary of his expenditures. Respondent reviewed
petitioner’s documents and, after performing a perfunctory
analysis, contends that most of the expenditures were for
transportation and entertainment. Respondent further contends
that the submitted documents do not meet the more stringent
requirements of section 274(d). Petitioner, on the other hand,
contends that all of the relevant expenditures represented by
these documents were incurred in connection with his financial
consulting business activity.
At trial, petitioner testified that the original documents,
which substantiate his claimed job expenses and other
miscellaneous deductions, are on his hard drive and in files at
Merrill Lynch. However, petitioner has not submitted those
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