J.J. Zand - Page 55

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          $24,500 for cash expenses, $15,000 for a London apartment, and              
          $10,000 for his Kitzbuhel apartment.  Also included were resident           
          membership dues for the Columbus Country Club as well as airline            
          tickets and hotel bills for Diesel Power employees and their                
          families.  While petitioner claimed $24,500 for cash expenses,              
          his travel diary showed no more than $9,946 in cash expenses.               
          Some of these were for personal rather than business expenses.              
               Petitioner's 1975 workpapers failed to show the amounts of             
          the checks that he wrote for cash in 1975.  Instead, the cash               
          expense was an estimate based on 270 travel days.                           
               Additionally, the return preparer saw no supporting records,           
          canceled checks, or other documents to support the $15,000                  
          claimed for the London apartment or the $10,000 claimed for the             
          Kitzbuhel apartment.                                                        
               Therefore, petitioner is not entitled to a deduction for               
          1975 travel and entertainment expenses in excess of the amount              
          allowed by respondent.                                                      
                                         1976                                         
               Although petitioner claimed a deduction of $98,578.45 for              
          travel and entertainment expenses on his 1976 tax return, only              
          $71,565.24 was recorded in CTC's disbursements journal.                     
          Petitioner claimed cash expenses of $15,000, but his travel diary           
          showed no more than $7,430 in cash expenses.  Similarly, expenses           
          of $5,000 claimed for Kitzbuhel are not substantiated.                      





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