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for carrying on any trade or business, (3) an expense, (4) a
necessary expense, and (5) an ordinary expense. See Commissioner
v. Lincoln Sav. & Loan Association, 403 U.S. 345, 352 (1971). In
addition to the requirements of section 162(a), petitioner must
also satisfy the substantiation requirements of section 274(d)
with respect to travel, meals and entertainment expenses.
Section 274(d) requires the evidence or records substantiating
said expenses to show:
(A) the amount of such expense or other item, (B) the time
and place of the travel, entertainment, amusement,
recreation, or use of the facility or property, * * * (C)
the business purpose of the expense or other item, and (D)
the business relationship to the taxpayer of persons
entertained, using the facility or property * * * *
Petitioner has submitted a copy of his 1994 American Express
Card statements, with copies of receipts attached thereto, as
proof of his entitlement to deduct travel and meals and
entertainment expenses. Although petitioner's American Express
Card statements show the place, amount, and date of a given
expense, we have no way of determining which of these expenses
petitioner deducted on his 1994 Federal income tax return or
whether any of these expenses were germane to the conduct of his
consulting business. Furthermore, the American Express
statements do not meet the substantiation requirements of section
274(d) because, among other things, they do not show the business
purpose of the expense or, with regard to entertainment expenses,
information on the persons entertained. Since petitioner has
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