Shizuo George Kurata - Page 14

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            that he is entitled to deduct travel and travel related expenses                          
            incurred in California in the pursuit of his business as a                                
            contract engineer.  Respondent asserts that petitioner did not                            
            maintain a tax home during 1989.  In addition, respondent                                 
            contends that petitioner's claimed expenses are not ordinary and                          
            necessary business expenses under section 162 and that petitioner                         
            has failed to meet the substantiation requirements of section                             
                  Petitioner testified that he incurred the claimed business                          
            expenses and that he provided the required substantiation to the                          
            Internal Revenue Service.  Petitioner, however, has failed to                             
            corroborate his testimony.  The record is barren of the type of                           
            substantiation required by section 274(d).  Petitioner did not                            
            provide the Court with any records or other evidence setting                              
            forth the amount, time, place, and business purpose of the                                
            expenditures claimed.  See sec. 1.274-5, Income Tax Regs.  So,                            
            even if the Court were to assume, arguendo, that petitioner's                             
            travel and travel related expenditures are deductible under                               
            section 162(a)(2), petitioner's failure to substantiate any of                            
            those expenses pursuant to section 274(d) requires disallowance                           
            of the claimed deduction.  Thus, respondent's adjustment                                  
            increasing petitioner's taxable income as a result of the                                 
            disallowed employee business expense deduction is sustained.                              

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