Les B. Martin and Millie A. Martin - Page 19

          entitled to a deduction for any of the claimed Schedule C expenses          
          for 1989 or 1990, except to the extent allowed in the statutory             
          notice of deficiency.                                                       
          Miscellaneous Itemized Deductions                                           
               For 1990, petitioners claimed $7,176 of miscellaneous itemized         
          deductions.  Petitioners provided no documentary evidence to                
          support their conclusory testimony that they incurred these                 
          deductions.  Although sworn testimony may suffice as proof, when it         
          is so general and conclusory in character (as it was here), it will         
          not be sufficient to satisfy petitioners' burden of proof.   See            
          Hearn v. Commissioner, 36 T.C. 672, 673-674 (1961), affd. 309 F.2d          
          431 (9th Cir. 1962).                                                        
               In addition, since the majority of these expenses are for              
          travel and entertainment, they are subject to the special                   
          substantiation provisions of section 274(d), and hence normally can         
          not be substantiated by testimony alone.  Consequently, we sustain          
          respondent's disallowance of petitioner's claimed deduction in 1990         
          for miscellaneous itemized deductions.                                      
          Accuracy-Related Penalty                                                    
               Finally, we must decide whether petitioners are liable for the         
          accuracy-related penalty under section 6662(a) for 1989 and 1990.           
          Section 6662 imposes a penalty equal to 20 percent of the portion           
          of the underpayment that is attributable to negligence or disregard         
          of rules or regulations.  Sec. 6662(a) and (b)(1).                          

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