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dividends from petitioner corporation. We conclude that
petitioner had dividend income of $164,224 in 1987.
3. Travel and Entertainment Expenses
Respondent disallowed $196,672 claimed by petitioner
corporation as travel and entertainment deductions. Respondent’s
determination is presumed to be correct, and petitioner
corporation bears the burden of proving otherwise. Rule 142(a);
Welch v. Helvering, supra at 115.
As discussed above at par. B-1 (pp. 14-15), we did not admit
into evidence petitioner’s exhibits purporting to substantiate
some of petitioner corporation’s travel and entertainment
expenses. Also, petitioner did not offer numerous other
documents also purporting to substantiate travel and
entertainment expenses. Even if the documents offered by
petitioner were in evidence, the exhibits (consisting mainly of
expense reports and Xerox copies of hotel, restaurant, and other
receipts) did not adequately substantiate any of petitioner
corporation’s travel and entertainment expenses. Most of them
did not indicate the business purpose for the expense.
Petitioner did not testify about the travel and entertainment
expenses. Thus, there is no evidence that petitioner corporation
incurred travel and entertainment expenses, the amount thereof,
or the business purpose for the expenses. Secs. 6001, 274; Rule
142(a). Petitioner corporation did not address this issue on
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