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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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Last modified: May 25, 2011