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interest expense because that interest payment related to the
$103,000 he received from Dean Witter, which petitioner claims he
used for investment purposes.
Petitioner has not established that he used the $103,000
loan proceeds for investment purposes. Petitioner fails to make
any argument regarding the remaining $2,000 in claimed interest
expense. Petitioner has failed in his burden of proof on this
issue.
We sustain respondent's disallowance of petitioner's $5,433
claimed investment interest expense deduction for 1991.
1992 -- Claimed Business and Other Deductions
Section 274(a) and (d) allows deductions for certain meal
and entertainment expenses, including dues for membership in
social clubs. To be deductible, such expenses must be directly
related to taxpayers' active conduct of a trade or business.
With regard to business expenses for meals and
entertainment, section 274(a) limits the deduction to those
expenses incurred directly preceding or following a bona fide
business discussion relating to the taxpayers' active conduct of
a trade or business. Sec. 274(a)(1)(A) and (2)(A).
The substantiation required for meal and entertainment
expenses should include the nature (including the amount, time,
and place of the meal or entertainment), the business purpose of
the claimed business expense, and the business relationship to
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