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Furthermore, it is clear that, since petitioner reported $37,850
in gross receipts, he must have incurred some business expenses.
Thus, respondent's complete disallowance of petitioner's
deductions cannot be sustained. Nor can petitioner's deductions
be allowed in full, as he has not satisfied the stringent
requirements of section 274(d). Section 274(d) requires
petitioner to substantiate the business use of his automobile or
other property used as a means of transportation by keeping
adequate records of his business use. Further, section 274(d)
requires petitioner to substantiate his travel and entertainment
expenses. Petitioner has not provided the Court with any
evidence to support these expenditures. Since petitioner failed
to do so, he is not entitled to such deductions.
Accordingly, we sustain respondent's disallowance of
petitioner's deductions for car and truck, travel and
entertainment, airline travel, hotel, taxi, and bus expenditures.
The remaining deductions claimed are allowed.
Addition to Tax Under Section 6651(a)
Respondent determined an addition to tax under section
6651(a) for failure to file a return. Petitioner asserts that he
is not liable for this addition to tax. Under section 6012(a),
petitioner was required to file a return for 1986. In light of
the foregoing, we sustain the addition to tax.
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