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if admitted, exhibit 104 would not prove the deductibility of the
additional travel and entertainment expenses. In addition to
petitioners’ burden under section 162(a) of proving that the
expenses were ordinary and necessary business expenses, section
274(d) imposes a stringent substantiation requirement for
deductions for travel and entertainment expenses. Under section
274(d), no deduction will be allowed for travel and entertainment
expenses unless the taxpayer substantiates these expenses by
adequate records or by sufficient evidence corroborating the
taxpayer’s own statement regarding: (1) The amount of such
expense or other item; (2) the time and the place of the travel
and entertainment; (3) the business purpose of the expense; and
(4) the business relationship to the taxpayer of the person
entertained. Sec. 274(d); sec. 1.274-5, Income Tax Regs.
While exhibit 104 is a fairly comprehensive compilation of
airline, rental car, hotel, and entertainment receipts, none of
these receipts describes the business purposes of the trips or
entertainment expenses. Petitioner’s testimony is the only
evidence of the business purposes of the trips, and his
uncorroborated testimony of the business purposes of the trips
fails to satisfy the substantiation requirements of section
274(d). Sec. 1.274-5, Income Tax Regs. We therefore sustain
respondent's determination disallowing the travel and
entertainment expenses.
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