Eugene C. Joseph, Sr. - Page 9

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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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