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Petitioner reported $7,538 gross receipts from this activity on
his 1982 tax return. Supra table 3. We conclude from the foregoing
that petitioner is entitled to deduct these $1,062 1982 farm
expenses on Schedule F.
Petitioner spent $3,623 on 1982 travel and entertainment; he
claimed travel and entertainment deductions of $8,922, $2,440, and
$5,782 on his tax returns for 1983, 1985, and 1986, respectively.
Petitioner has failed to meet the substantiation requirements
of section 274, even taking into account the provisions of section
1.274-5(c)(5), Income Tax Regs., and so no deduction is allowable
for these expenditures. Sec. 274(d); Sanford v. Commissioner, 50
T.C. 823, 827-828 (1968), affd. 412 F.2d 201 (2d Cir. 1969).
Petitioner, whose listed Schedule C trade or business during
each of the years in issue is "attorney", is entitled to deduct on
Schedule C his Oklahoma Bar Association dues, the $1,644 he spent
on law books in 1982, and his law practice office expenses. As to
petitioner's overall office expenses, we are once again faced with
an inadequate record. We have examined the incomplete records in
evidence as to 1982. and 1983, and we are satisfied that
petitioner spent at least $27,000 in 1982 and at least $8,000 in
1983 for law practice office expenses, that he is entitled to
deduct on Schedule C. At trial, petitioner estimated that only
about $10,000 of his $78,595 claimed 1984 Schedule C deductions
related to his law practice. Doing the best we can, bearing
heavily against petitioner, we conclude (and we have found) that
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