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establish that the deduction was for an ordinary and necessary
business expense or was expended for the purpose designated on
the 1989 tax return. The 1989 tax return indicates that
petitioner claimed the deduction for vehicle expenses, travel
expenses, and meal and/or entertainment expenses.
Section 162(a)(2) permits a deduction for traveling
expenses, including amounts expended for meals and lodging,
incurred by a taxpayer while away from home in the pursuit of a
trade or business. The taxpayer must demonstrate that the
expenses were (1) reasonable and necessary traveling expenses,
(2) incurred “while away from home”, and (3) incurred in the
pursuit of business. See, e.g., Commissioner v. Flowers, 326
U.S. 465, 470 (1946). In addition, section 274(d) imposes strict
substantiation requirements. Section 274(d) provides that, with
certain inapplicable exceptions, no deduction for traveling
expenses (or similar items) shall be allowed
unless the taxpayer substantiates by adequate records
or by sufficient evidence corroborating the taxpayer's
own statement (A) the amount of such expense or other
item, (B) the time and place of the travel,
entertainment, amusement, recreation, or use of the
facility or property, or the date and description of
the gift, (C) the business purpose of the expense or
other item, and (D) the business relationship to the
taxpayer of persons entertained, using the facility or
property, or receiving the gift. * * *
At trial, petitioner stated that, in 1989, he maintained
“tax homes” in Arlington, Texas, and Everett, Washington, while
working as a contract engineer in California. Petitioner claims
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