- 8 -
which he showed to her shortly before trial. Based on her review
of his records and his statements during the examination, Ms.
Coopersmith testified that she determined that petitioner was not
entitled to a deduction for meals and entertainment expenses in
excess of the amount allowed in the statutory notice of
deficiency. Respondent submitted a computer printout of the
results of Ms. Coopersmith's examination as part of the record in
this case; she stated to the Court that the computer printout was
her summary of the amounts substantiated by petitioner and
allowed by her.
After reviewing the daily planner and the weekly charts,
examining petitioner's records, and listening to petitioner's
testimony, we find that Ms. Coopersmith correctly concluded that
the meals and entertainment expenses allowed in the statutory
notice of deficiency equal or exceed the amount substantiated by
petitioner's records and statements. It appears from the record
that respondent went to great lengths to sort through
petitioner's assorted records only a week before the trial in an
effort to allow petitioner all of the deductions to which he was
entitled. Petitioner's records do not support a finding
different from respondent's determination, and he failed to
provide any testimony which convinces us that respondent erred in
his determination. We therefore hold that petitioner is not
entitled to a Schedule C deduction for meals and entertainment
expenses in excess of the amount allowed by respondent.
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