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Petitioner's testimony regarding these expenses was vague,
general, and dubious. Petitioner alleges that he did not bill
clients of his investigation business for such charges because he
was trying to build his business. The invoices submitted at
trial, however, establish that petitioner did indeed bill his
clients for equipment, supplies, and photographs. The fact that
some receipts have job numbers further supports our finding that
petitioner was keeping track of expenses to bill clients.
Moreover, in 1991 petitioner claimed over $200 in photo expenses.
However, in many instances petitioner deducted these expenses
twice by submitting both a photo receipt and a photo envelope for
the same item and then claiming them as two separate expenses.
For 1992, petitioner deducted $120 ($10 per month times 12
months) for business checking fees. Petitioner did not submit
bank statements to substantiate this expense. Accordingly, we
sustain respondent's disallowance of deductions claimed for
supplies and office expenses.
F. Travel, Meals, and Entertainment
For 1991 and 1992, petitioner deducted $1,589 and $2,448,
respectively for travel, and $2,867 and $2,156, respectively, for
meals and entertainment. Respondent disallowed these amounts for
lack of substantiation. We find for respondent on this matter.
A taxpayer is required under section 274(d) to substantiate
entertainment expenses by adequate records to corroborate his or
her own testimony as to: (1) The amount of the expense, (2) the
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