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so, it follows that the mileage expenses for each year are
nondeductible commuting expenses.
Travel, Meals, and Entertainment
For 1992 and 1993, petitioner claims $120 and $180,
respectively, for travel expenses, and $640 and $960,
respectively, for meals and entertainment expenses. For 1994 and
1995, petitioner claims $425 and $300, respectively, for meals
and entertainment expenses. Respondent disallowed all of
petitioner's claimed expenses.
A taxpayer is required under section 274(d) to substantiate
travel, meals, and entertainment expenses by either adequate
records or sufficient evidence corroborating the taxpayer's own
statement as to: (1) The amount of the expense, (2) the time and
place the expense was incurred, (3) the business purpose of the
expense, and (4) the business relationship to the taxpayer of
each expense incurred. In the absence of evidence meeting these
strict substantiation requirements, deductions for travel, meals,
and entertainment expenses are not allowed. See Whalley v.
Commissioner, T.C. Memo. 1996-533; sec. 1.274-5T(b)(4), Temporary
Income Tax Regs., 50 Fed. Reg. 46015 (Nov. 6, 1985).
Other than his oral testimony, petitioner did not provide
substantiation of his expenses for travel, meals, and
entertainment. Accordingly, petitioner has failed to meet the
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