- 137 - 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,Page: Previous 127 128 129 130 131 132 133 134 135 136 137 138 139 140 141 142 143 144 145 146 Next
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