Darryl F. Royster - Page 28




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          credible, however, that the checks written to the AAU and the               
          Western Springs Rec Center were for RBS-related expenses incurred           
          with basketball school sessions and tournament entry fees that              
          occurred contemporaneous to their payment.  Specifically, and for           
          purposes of our decision, the record includes checks drafted to             
          the AAU and the Western Springs Rec Center in the following                 
          amounts:                                                                    
                                   2000           2001           2002                 
          Checks drafted to:                                                          
               AAU            $642           $2,664         $400                      
               Western Springs                                                        
               Rec Center          521             380            200                 
          Total               1,163          3,044               600                  
               As to the remainder of the canceled checks, we find                    
          petitioner’s testimony and the receipt provided for Western                 
          Springs Rec Center credible to substantiate only the foregoing              
          expenses.                                                                   
               The hotel receipts provided correspond to petitioner’s                 
          credible testimony regarding tournaments that RBS entered in                
          2000, and therefore, we hold that petitioner has satisfied the              
          heightened substantiation requirements under section 274(d) with            
          respect only to these expenses--$3,870.04 for taxable year 2000.            
               As to the remaining items, the American Express statement,             
          and an itemized cellular phone bill, neither the credit card                
          statement nor the phone bill rises to the substantiation standard           
          required.  The American Express statement is for an account held            






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