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dates of departure and return for each trip, and the number of
days spent on business, (3) the place of travel, and (4) the
business benefit derived by the taxpayer for each trip. Sec.
1.274-5(b)(2), Income Tax Regs.
At trial, petitioner's testimony regarding his travel, meal,
and entertainment expenses was vague and in many instances
incoherent. Although petitioner submitted various receipts and a
personal diary for each tax year establishing that he incurred
expenses, these documents fail to establish the business purpose
and business relationship of these expenses. Accordingly,
petitioner has failed to meet the strict substantiation
requirements of section 274(d), and we, therefore, sustain
respondent's determination for the taxable years in issue.
Issue 3. Home Office Deductions
Respondent determined that petitioner is not entitled to a
home office deduction for the taxable years in issue. Petitioner
asserts that during 1979 his home office was used for many
meetings "with the bank people, and with Greenbaum and Dickey,
plotting our escape from our respective firms." Similarly, in
1980, petitioner asserts that he used his home office to meet
with clients from Robinson and Silverman and to wind down his old
business.
Section 280A generally prohibits the deduction of otherwise
allowable expenses with respect to the use of an individual
taxpayer's home. Section 280A(c)(1) provides a narrow exception
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