J.J. Zand - Page 169

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               No attempt has been made to show that claimed travel and               
          entertainment expenses in any amounts greater than those allowed            
          by respondent were ordinary and necessary or were expended in               
          furtherance of CTC's business, rather than in furtherance of                
          Diesel Power's business or the business of other entities in                
          which petitioner was involved.  Instead, petitioner ignores the             
          existence of any other entities on whose behalf he conducted                
          business and merely concludes that an expense was CTC related if            
          it was treated that way on CTC's books or by his tax return                 
          preparers.  None of petitioner's bookkeepers or return preparers            
          testified that they were present when any expense was incurred;             
          rather, petitioner simply directed how an expense was to be                 
          treated on CTC's books.  Accordingly, their testimony does                  
          nothing to substantiate the business nature of travel and                   
          entertainment amounts reflected on either CTC's books or                    
          petitioner's tax returns.  See Anderson v. Commissioner, T.C.               
          Memo. 1976-28 (testimony of bookkeeper who was not present when             
          expenses were incurred could not substantiate nature of claimed             
          travel and entertainment expenses).                                         
               In addition to the requirements that expenses be ordinary              
          and necessary as well as in furtherance of taxpayer's business,             
          section 274(d) imposes stringent substantiation criteria.                   
          Section 274(d) prohibits a deduction for travel and entertainment           
          expenses unless the taxpayer substantiates by adequate records or           





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