Magdy S. Ellabban - Page 7

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          did not testify or provide any evidence about his gas expenses or           
          tolls.  Petitioner did not have a log, records, or other                    
          corroboration showing the mileage, dates, locations, or business            
          purpose of any of the vehicle trips as required under section               
          274(d)(4).  We conclude that he may not deduct more than                    
          respondent has allowed.                                                     
               3.   American Express Charges                                          
               Petitioner contends that he used his American Express credit           
          card to pay $11,278 more than respondent allowed for Elan’s                 
          expenses.  He testified that the payments were for business                 
          meals, but he conceded that he could not substantiate that any of           
          these meals had a strict business purpose.  Petitioner has not              
          met the substantiation requirements of section 274(d)(1).                   
               4.   Depreciation                                                      
               Petitioner contends that respondent should have allowed Elan           
          to claim an additional $3,090 for depreciation.   We disagree.              
          Elan is not a party here; even if it were, petitioner has not               
          offered any evidence to show that Elan is entitled to additional            
          depreciation.                                                               
               5.   Conclusion                                                        
               We conclude that petitioner paid $26,134 of Elan’s business            
          expenses from the $146,193 which he received for Elan but did not           
          deposit in Elan’s bank account.                                             







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