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expense; and (4) the business relationship to the taxpayer of
persons entertained. The regulations make it clear that section
274(d) supersedes the doctrine of Cohan v. Commissioner, supra,
and that a deduction for travel and entertainment must be
supported by more than approximations or unsupported testimony of
a taxpayer. Sec. 1.274-5(a), Income Tax Regs. Under section
274(d), every expenditure claimed as a deduction must be
substantiated by the taxpayer by either adequate records or other
sufficient evidence, and his or her failure to do so will cause
such expenditures to be disallowed in full. See Sanford v.
Commissioner, 50 T.C. 823, 828-829 (1968), affd. per curiam 412
F.2d 201 (2d Cir. 1969).
Petitioner offered into evidence copies of several receipts
from various restaurants, as well as tickets to sporting events
and theaters. Petitioner also offered into evidence various
canceled checks to evidence travel expenses. However, these
items were not shown to be related to Mr. Velinsky's business,
except by petitioner's testimony that she never saw her husband
retain receipts for nonbusiness meals and entertainment, and that
her husband often took business trips. There was no record of
the business purpose of the travel or claimed entertainment. The
record does not show the persons present at any meetings, and, in
most cases, the time and place of the meetings or entertainment
are not shown. We, therefore (under section 274(d)) sustain
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