- 17 -
discussed during any such meals. Based on the instant record, we
find that petitioner has failed to establish that the meal expen-
ses incurred during 1989 were ordinary and necessary expenses
that were incurred in connection with his rental real estate
activities.
Petitioner also failed to establish that he satisfied the
substantiation requirements of section 274(d).10 A taxpayer may
satisfy the substantiation requirements of section 274(d) by
adequate records or by sufficient evidence corroborating his or
her own statement. Sec. 1.274-5(c)(1), Income Tax Regs. To meet
the adequate records requirements of section 1.274-5(c)(1),
Income Tax Regs., a taxpayer must keep an account book, diary, or
similar document that records information required by section
10 Sec. 274(d) provides in pertinent part:
(d) SUBSTANTIATION REQUIRED.--No deduction or credit
shall be allowed--
* * * * * * *
(2) for any item with respect to an activity which is
of a type generally considered to constitute entertainment,
amusement, or recreation, or with respect to a facility
used in connection with such an activity,
* * * * * * *
unless the taxpayer substantiates by adequate records or by
sufficient evidence corroborating the taxpayer's own state-
ment (A) the amount of such expense or other item, (B) the
time and place of the * * * entertainment, amusement, re-
creation, or use of the facility or property, * * * (C) the
business purpose of the expense or other item, and (D) the
business relationship to the taxpayer of persons enter-
tained * * *.
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