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business purpose. See Moylan v. Commissioner, T.C. Memo. 1968-15
(expenses of golf outings disallowed where taxpayer did not show
direct relationship between expense and conduct of business);
sec. 1.274-5T(b)(3), Temporary Income Tax Regs.
We sustain respondent’s adjustment to petitioner’s meals and
entertainment expense deduction as modified.
Wage Expense
On his 1994 Schedule C, petitioner claimed a deduction for
wages in the amount of $2,340. The items allegedly included in
calculating the deduction were listed on an exhibit entitled
“1994 Wage Expenses”. Petitioner contends that he paid various
people amounts from $30 to $250 for clerical and research work
and for computer training.
Petitioner did not maintain any documentation regarding the
alleged wage payments. Although he claimed that he made the
payments in cash, he did not obtain any receipts for the
payments.
The record is devoid of any credible evidence substantiating
the alleged wage payments. As a businessperson, petitioner
surely knew that he was required to substantiate his business
deductions. Petitioner failed to offer any evidence other than
his own testimony to prove that he actually made the wage
payments. We are not required to accept a taxpayer’s self-
serving and uncorroborated testimony. See Wood v. Commissioner,
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