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of petitioner's hotel expenses in that year. The only evidence
to support the business purpose for this payment is petitioner's
testimony that Diesel Power paid his hotel expenses in all but 1
year, and notations on CTC's 1974 disbursements journal and
workpapers. Moreover, there is no breakdown of this total amount
by date or place, nor is there evidence establishing that any
portion of the payment was incurred for a business purpose of
CTC, rather than of Diesel Power. In these circumstances, we
hold that the $27,618.39 payment is not a deductible expense.
In his brief petitioner makes no legitimate argument in
support of his claimed travel and entertainment expenses. He
merely asserts that the respondent's disallowance of the expenses
was arbitrary because respondent allowed the amounts set forth on
CTC's journals in 1974 and 1976, but subsequently took a
"shotgun" approach, disallowing one-half of the amounts on CTC's
journals in 1975 and completely disallowing the amounts reflected
on the journals for the years 1977 through 1981. Contrary to
petitioner's claim, CTC's 1975 disbursements journal shows travel
and entertainment expenses of $108,446.48. However, on his 1975
return petitioner claimed a deduction in the total amount of
$157,946.48. For 1975 respondent allowed him $80,631.47 or
approximately 75 percent of the amount reflected on CTC's
journals. For the years 1977 through 1981 petitioner was
involved in a myriad of other entities in addition to CTC, his
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