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none of them had independent knowledge pertaining to his
underlying claimed expenses for travel and entertainment.
By the Court's Order dated October 9, 1992, summaries of the
diaries for 1973 (Pet. Exh. 3114), 1974 (Pet. Exh. 3116), 1975
(Pet Exh. 3118), 1976 (Pet. Exh. 3119), 1977 (Pet. Exh. 3120),
1978 (Pet. Exh. 3195), and 1979 (Pet. Exhs. 3202 and 3206), were
not received in evidence. Additionally, because there were no
diaries for 1980 and 1981, the Court did not receive in evidence
petitioner's summaries (Exhs. 3209, 3211, and 3214) of travel and
entertainment expenses claimed for those years.
Petitioner's diaries do not meet the "adequate records"
substantiation requirements necessary to deduct travel and
entertainment expenses pursuant to section 274.
1973
Although petitioner claimed a deduction of $98,481.64 on his
1973 tax return for travel and entertainment expenses, only
$80,192.81 was recorded in CTC's disbursements journal.
Petitioner claimed cash expenses of $17,500, but his travel diary
showed no more than $8,154 in cash expenses. Some of these were
for personal rather than business expenses. His return preparer
estimated petitioner's cash expenses by comparing the number of
checks petitioner wrote for cash with the number of days his
diary shows he was out of the United States. No allowance was
made for any personal travel. Hence, petitioner is not entitled
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