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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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