Alonzo and Emma J. Bradley - Page 14

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          into evidence copies of receipts for food and gasoline totaling             
          $232.77 and a copy of an airline ticket in the amount of $318.              
          Mr. Bradley testified that he incurred the food and gasoline                
          expenses in an attempt to generate interest in the property by              
          showing it to a friend from Houston and holding a picnic for                
          local residents.  He testified that the airline ticket was                  
          purchased to meet with a former business partner in Chicago to              
          discuss developing the land as a low-income housing project.                
          Since the foregoing expenses are for travel and entertainment               
          they must, in addition to meeting the requirements of sections              
          162 or 212, be substantiated in accordance with the requirements            
          of section 274(d).  Since petitioners have not substantiated the            
          business purpose of the foregoing expenditures with a written               
          explanation, see sec. 1.274-5T(c)(2)(ii)(B), Temporary Income Tax           
          Regs., 50 Fed. Reg. 46018 (Nov. 6, 1985), or corroborated Mr.               
          Bradley's statements with direct or circumstantial evidence of              
          the time, place, or business purpose of the expenditures, see               
          sec. 1.274-5T(c)(3)(i), Temporary Income Tax Regs., 50 Fed. Reg.            
          46020-46021 (Nov. 6, 1985), we find the receipts and Mr.                    
          Bradley's testimony insufficient for purposes of section 274(d)             
          substantiation and therefore sustain respondent's determination             
          disallowing the auto and travel expenses.                                   
               With respect to the disallowance of a $1,500 management fee            
          claimed on Schedule E for the Mississippi land, petitioners                 
          offered a copy of a check made out to "DECA Corp." as payee in              




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