Joseph Baldwin Campbell - Page 19

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            connection with a profit-motivated trade or business.11  Further,                            
            respondent argued, petitioner's participation as a member of the                             
            EPC was not regular, continuous, and with the primary purpose of                             
            making a profit as required by section 162.  Finally, respondent                             
            argued, petitioner failed to substantiate the amount of his                                  
            travel expenses incurred away from home, as required by section                              
                  The expenses petitioner claimed were travel expenses                                   
            incurred with respect to trips taken by petitioner in connection                             
            with his duties as spokesperson for the EPC.  Petitioner                                     
            introduced into evidence a computer-generated printout, which he                             
            had prepared in anticipation of trial, of the amounts and                                    
            descriptions of his claimed expenses.  However, petitioner failed                            
            to produce any receipts or other similar corroborative evidence                              
            to substantiate the various amounts, times, places, or business                              
            purposes of his claimed expenses.  In short, petitioner failed to                            
            introduce any documentary evidence sufficient to support his                                 
            claimed expenses incurred in connection with his duties as a                                 
            member of the EPC.                                                                           
                  The Court finds that petitioner's records are insufficient                             
            to satisfy the stringent substantiation requirements of section                              
            274(d).  In the case of travel expenses, specifically including                              

                  Petitioner admitted at trial that his position with the EPC                            
            was a volunteer position.                                                                    

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