Marian Wilson - Page 15

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          and Los Angeles.  In 1993, petitioner contends that Faye Oatis              
          and Linda Klyce traveled to San Diego and Yuma.                             
               Petitioner has stipulated that Special O's claimed travel              
          expenses for the years at issue were paid from the personal funds           
          of petitioner or her sisters.  Petitioner has failed to establish           
          that any of the claimed travel expenses were reimbursed by                  
          Special O.  A corporation is not entitled to deduct unreimbursed            
          shareholder expenses.  See Lang Chevrolet Co. v. Commissioner,              
          T.C. Memo. 1967-212.                                                        
               Additionally, both Special O and petitioner have failed to             
          provide this Court with either adequate records or sufficient               
          evidence corroborating the claimed travel deductions.  Taxpayers            
          must substantiate any deductions claimed.  See Hradesky v.                  
          Commissioner, 65 T.C. at 90.                                                
               Section 162(a) allows a taxpayer to deduct "all the ordinary           
          and necessary expenses paid or incurred * * * in carrying on any            
          trade or business".  Section 274(d) requires strict                         
          substantiation of certain expenses including those incurred with            
          respect to meals, travel, and entertainment.                                
               We hold that Special O is not entitled to claim travel                 
          expenses in the amounts of $740.81, $2,497, and $1,529 for the              
          1991, 1992, and 1993 tax years, respectively.  Respondent is                
          sustained on this issue.                                                    

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