John D. Shea - Page 9




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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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