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to independently corroborate his testimony. Petitioner proffered
canceled checks in connection with the travel expenses totaling
$18,475.86. However, checks alone do not meet the stringent
substantiation requirements of section 274(d). See also sec.
1.274-5(c)(2)(iii), Income Tax Regs. There were no receipts,
vouchers, itineraries, diaries, logs, and calendars made by
petitioner in connection with the alleged travel expenses.
Moreover, petitioner was unable to demonstrate that the travel
expenses bore a reasonable and proximate relationship to the
trade or business of his real estate proprietorship. See sec.
162(a).
Accordingly, we sustain respondent's determinations with
respect to these travel expenses.
D. Legal and Professional Service Expense Deduction
Petitioner claimed a deduction for legal and professional
expenses in the amount of $101,557.00 on Schedule C of his
Federal income tax return. Respondent disallowed the claimed
deduction on Schedule C and recharacterized it as a miscellaneous
itemized deduction under Schedule A.
The record concerning the legal fees consists mostly of
photocopies of checks to various attorneys, as well as
petitioner's own summary sheet of the legal expenses incurred.
Petitioner estimated that $80,000 of the legal fees was expended
in connection with the lawsuit concerning the general contracting
activity.
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