Kenneth Andrew Baratelle - Page 19




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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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