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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
274(d).
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
11
Petitioner admitted at trial that his position with the EPC
was a volunteer position.
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