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Amount Claimed Amount Allowed Amount Disallowed
Year by Petitioner by Respondent by Respondent
1973 $98,481.64 $78,568.27 $19,913.37
1974 126,068.79 50,784.39 75,284.40
1975 157,946.48 80,631.47 77,315.01
1976 98,578.45 78,578.45 20,000.00
1977 60,184.00 -0- 60,184.00
1978 74,970.00 -0- 74,970.00
1979 41,444.00 -0- 41,444.00
1980 28,368.00 -0- 28,368.00
1981 19,604.00 -0- 19,604.00
Respondent disallowed the above travel and entertainment
expenses on the grounds that (1) they were not petitioner's
ordinary and necessary business expenses, (2) they were not
expended for the purposes designated, or (3) they were not
substantiated in accordance with the requirements of section 274.
For each of the years 1973 through 1979 petitioner kept a
travel diary that reflected both his location and the names of
individuals he met with and entertained. However, in most
instances the business purpose and the place of lodging or
entertainment are omitted. Many of the individuals named in the
diaries, particularly those for 1973 through 1976, had business
relationships with Diesel Power, WHIP, All Patents, and IGOS. No
witnesses named in petitioner's diaries provided testimony
corroborating any specific meeting, entertainment, or expense
reflected in the diaries. Furthermore, petitioner's employees
and office personnel acted pursuant to his directions; hence,
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