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or expenditure claimed in the diaries. In fact, the testimony of
Murat Seker and petitioner himself directly contradicts entries
in his diaries.
The unsupported testimony of a taxpayer at trial is not
sufficient to meet the stringent substantiation requirements of
section 274(d). To adequately substantiate the deductibility of
travel and entertainment expenses, specificity is imperative.
Dowell v. United States, supra at 714; Hatch v. Commissioner,
T.C. Memo. 1980-110; Gras v. Commissioner, T.C. Memo. 1974-230.
Petitioner attempts to surmount this specificity requirement
by contending in his brief that this case does not involve a
shoebox full of receipts, and that the sheer number of exhibits,
the length of trial, the mass of petitioner's brief, and
petitioner's selective testimony prove his entitlement to the
claimed travel and entertainment expenses. We reject his
contention. This same argument was rejected in Dowell v. United
States, 522 F.2d at 708, where the Court of Appeals for the Fifth
Circuit reversed the District Court's finding that the "blizzard"
of bills and chits established the amounts, dates, and places of
expenditures necessary to substantiate the taxpayer's claimed
travel and entertainment expenses. As recognized by the Court of
Appeals in Dowell, such an approach is contrary to the stringent
substantiation requirements imposed by section 274(d). Id. at
714.
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