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274(d) (including a written statement of the business purpose of
the expenditure) and that is prepared at or near the time the
expense is paid. Sec. 1.274-5(c)(2), Income Tax Regs. Where a
taxpayer fails to comply with the adequate records requirements
of that regulation, he or she may satisfy the substantiation
requirements of section 274(d) by (1) his or her own statement,
written or oral, that contains specific information in detail
relating to those substantiation requirements and (2) other
corroborative evidence sufficient to establish those require-
ments. Sec. 1.274-5(c)(3), Income Tax Regs.
Petitioner did not present any contemporaneous account book,
diary, or similar document that recorded information required by
section 274(d). In addition, petitioner testified in a general
manner about the meal expenses at issue, and his testimony did
not contain specific information in detail as to the business
purpose for those expenses and was not accompanied by any cor-
roborative evidence. Accordingly, petitioner failed to satisfy
the substantiation requirements of section 274(d).
Based on our review of the entire record in this case, we
sustain respondent's determination that petitioner is not en-
titled to deduct for 1989 the meal expenses at issue.
To reflect the foregoing and petitioner's concessions,
Decision will be entered for
respondent.
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Last modified: May 25, 2011