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credible evidence in the record to prove that petitioner paid for
the airfare. Petitioner’s airfare could have been paid by a
third party or purchased with frequent flier mileage. On this
record, we simply do not know what happened. Section 274(d)
requires more substantiation than simply a taxpayer’s testimony.
See Langer v. Commissioner, T.C. Memo. 1990-268 (deduction for
airfare disallowed without receipt), affd. 980 F.2d 1198 (8th
Cir. 1992).
Likewise, petitioner had no receipts or other documentation
to support his deduction of lodging, meals, and golf. These
expenses also are subject to the requirements of section 274(d),
and the requirements have not been met in this case. See also
sec. 1.274-5T(b)(2) and (3), Temporary Income Tax Regs.
Although petitioner had receipts for expenditures at the Tee
& Sea Resort and the Bay Tree, petitioner did not substantiate
the nature of the expenditures or their business purpose.
Petitioner claimed that the Bay Tree expense was for lodging, but
this does not appear to be the case. Respondent already has
conceded petitioner’s lodging expenses of $547 for that trip.
Petitioner offered no explanation for the Tee & Sea Resort
expense.
We sustain respondent’s adjustment to petitioner’s travel
expense deduction as modified.
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