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substantial and stringent requirements of section 274(d). The
other category consists of all the other claimed deductions.
Regarding the deductions governed by section 274, respondent
has conceded some items of expense, and petitioner has conceded
that the air travel expenses in all the years in issue cannot be
adequately substantiated. Petitioner has put forward no
believable explanation for the absence of required records;
consequently, the burden of his inexactitude must fall on him.
Petitioner did not produce any witnesses to corroborate when and
where he traveled on business. Mrs. Shea could testify only to
the fact that petitioner was not home and that petitioner said he
was traveling on business. While it is likely that some of
petitioner's travel was business related, we have insufficient
information to allow any deductions given the strict standards
set by section 274. Petitioner's claims for deductions relating
to meals away from home and lodging expenses fail for the same
reasons that the airline travel expenses fail. The other claimed
deductions subject to section 274(d), including passenger auto
expense and entertainment, are likewise unsubstantiated.
Petitioner did not keep a contemporaneous trip diary to record
business miles traveled in his personal vehicle and did not
maintain a record of the parties entertained or the business
purpose. We, consequently, uphold respondent's disallowance of
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