Greta Ann Clifton - Page 18

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          receipt for a camper top and running boards, among other things,            
          for her truck.                                                              
               In total, the amounts paid to American Appliance and the               
          amounts paid for improvements to the truck equal the amount                 
          disallowed by respondent--$2,412.  Petitioner has failed to prove           
          that any of these disallowed amounts was a necessary expense for            
          a business, rather than personal, purpose.  Therefore, petitioner           
          failed to sustain her entitlement to a deduction for supplies in            
          any amount greater than $2,174.  Accordingly, we sustain                    
          respondent's determination.                                                 
               F.  Travel and Entertainment Expenses                                  
               Petitioner claimed a deduction of $446 on her 1985 Federal             
          income tax return for travel and entertainment.  Respondent                 
          determined that petitioner was not entitled to this deduction.              
               Section 274(d) requires that the taxpayer substantiate by              
          adequate records or by sufficient evidence corroborating her own            
          statement expenses claimed for travel and entertainment by                  
          showing (1) the amount of the expense, (2) the time and place of            
          travel or entertainment, (3) the business purpose of the travel             
          or entertainment, and (4) the business relationship to the                  
          taxpayer of each person entertained.  These four elements must be           
          established for each separate expenditure.  Sec. 1.274-5(c)(1),             
          Income Tax Regs.                                                            
               Petitioner presented a schedule showing the breakdown of the           
          $446 deduction claimed -- expenditures in the amount $218, $119,            

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