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disallowance of travel and entertainment deductions. Sanford v.
Commissioner, 50 T.C. 823, 828 (1968), affd. per curiam 412 F.2d
201 (2d Cir. 1969).
In our view petitioner's travel diaries do not meet the
substantiation requirements necessary for purposes of section
274. The diaries do not reflect the business purpose of the
meeting, entertainment or expense, the location where the
entertainment took place, or the business relationship of the
person entertained. Instead, the diaries contain a hodgepodge of
cities, names of persons and, in some instances, an amount
allegedly paid for hotel bills, dinners and entertainment,
transportation, and miscellaneous expenses.
Some meetings, entertainment, and expenses reflected in the
diaries are clearly personal. For example, the diaries include
expenditures for luggage and clothes and reflect meetings and
entertainment in Rome, Beirut, London, and Paris with Murat Seker
of Ingersoll-Rand in January, February, and April 1973, April and
August 1975, March and May 1976, and April 1977. Both petitioner
and Mr. Seker testified that they had no business relationship in
the 1970's. Moreover, the diaries reflect expenses for dinners
and entertainment of entire families or unnamed associates. In
many instances the individuals whose names appear in the diaries
were involved not only with CTC, but also with Diesel Power,
WHIP, All Patents, IGOS in the earlier years, and McZand
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