Robert P. Petrocine - Page 11

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               Taxpayers generally bear the burden to substantiate claimed            
          meal, entertainment, and travel expenses.  Sec. 274(d)(1) and               
          (2); Rule 142(a).                                                           
               Petitioner argues that because he worked solely on                     
          commission as a stockbroker, all of his time spent at the Club              
          involved either the solicitation of potential clients or the                
          conduct of business with current clients, and therefore that the            
          $7,000 (after the statutory 2-percent adjustment) claimed as                
          business expenses incurred at the Glen Ridge Country Club should            
          be allowed.                                                                 
               Respondent argues that petitioner has adequately                       
          substantiated only $9,138 of the total $31,796 claimed expenses.            
               With respect to petitioner's claimed business expenses                 
          incurred at the Club, petitioner has failed to offer any credible           
          documentation to support the deduction of these expenses.                   
          Petitioner's records from the Club that are in evidence indicate            
          only the general category of expenses petitioner incurred, and              
          petitioner offers no records or other verification relating the             
          specific expenses incurred to specific business-related activity.           
               With respect to petitioner's other claimed expenses, we find           
          the record devoid of any documentation or other basis to support            
          any credible estimate.  Cohan v. Commissioner, supra.                       
               Petitioner has failed to meet his burden of proving that he            
          is entitled to any of the above claimed expense deductions other            
          than the $9,138 that respondent has allowed.                                




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