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for bona fide indebtedness from Speedmart. Accordingly, we
sustain respondent's determination on this issue.
II. Unreimbursed Partnership Expenses
A partner generally cannot directly deduct on his income tax
return the expenses of the partnership. See Cropland Chem. Corp.
v. Commissioner, 75 T.C. 288, 295 (1980). The exception to this
rule is where there is an agreement among the partners that such
partnership expenses shall be borne by particular partners out of
their own funds. Id. Where the exception applies, the partner
is entitled to deduct the amount of the expense from his
individual gross income.
Petitioner claimed on his individual income tax return
deductions for expenses incurred for entertainment and travel
related to partnership business. Petitioner bears the burden of
proving that he is entitled to the claimed deductions. Rule
142(a); New Colonial Ice Co. v. Helvering, 292 U.S. 435, 440
(1934). In addition, entertainment and travel expenses are
subject to the substantiation requirements of section 274(d).
That section provides that no deduction shall be allowed for
travel and entertainment expenses unless the taxpayer provides
adequate records to corroborate his deductions. Petitioner has
produced no records to substantiate his claimed deductions.
Therefore, we conclude that petitioner has not carried his burden
of proving that he is entitled to claimed deductions for travel
and entertainment expenses.
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