- 17 - expenses. Keating v. Commissioner, T.C. Memo. 1995-101; sec. 1.274-5(a), Income Tax Regs. Petitioner claims deductions with respect to: (1) Trips to Reno, Nevada, in 1990 and 1991; (2) a trip to Michigan in 1990, including expenses for his daughter, employed as a "research assistant"; (3) trips to Lake Tahoe, Nevada, in 1990 and 1992; and (4) a trip to Pacific Grove, California, in 1991. In a misguided attempt to protect the names of purported writing sources, petitioner has refused to provide sufficient evidence, such as contemporaneously prepared logs or diaries, from which we could ascertain the business purpose of his travel. Sec. 1.274- 5T(c)(2), Temporary Income Tax Regs., 50 Fed. Reg. 46017 (Nov. 6, 1985). Furthermore, we are convinced that some of petitioner's expenditures, such as the costs of travel to Michigan with his daughter to attend petitioner's mother's funeral and conduct "research" for Great Woods Poppy, were undoubtedly personal in nature. As petitioner has failed to meet the substantiation requirements of section 274(d), we sustain respondent's denial of all travel expenses. (G) Research Petitioner introduced canceled checks, attributable to a variety of expenditures, purportedly related to his literary research. While petitioner lists the amounts of expenditures, he failed to present any detailed evidence concerning the specific nature of each expenditure. Many of these expenditures arePage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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