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Proc. 93-21, 1993-1 C.B. 529, in support of his argument. That
revenue procedure relaxes some of the strict substantiation
requirements of section 274(d) under certain circumstances;
however, none apply to petitioner. Petitioner did not receive a
per diem allowance from any payor, and he did not incur the meals
expense as a self-employed individual. The revenue procedure
does not apply, and petitioner cannot rely upon it to support any
portion of the deduction claimed on his 1993 return or his claim
for an additional deduction.
Petitioner has failed to satisfy the requirements of section
274(d) with respect to any traveling expense that he might have
incurred in seeking employment as a school principal during 1993.
Therefore, he is not entitled to a deduction for any such
expense, and respondent's determination in this regard is
sustained.
Petitioner also now claims that he is entitled to an
additional deduction for unreimbursed travel expenses incurred as
an employee of the Department of Defense. Petitioner made a
claim to his employer for reimbursement, but his claim was denied
because it was submitted late. Assuming that the claim was
otherwise valid, had petitioner submitted the reimbursement claim
timely, the claim would have been paid. If a taxpayer is
eligible to be reimbursed for an expense from his or her employer
but fails to make a proper claim for reimbursement, the expense
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