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the climates for which he was required to sail without prior
notice.
On his 1994 Federal income tax return, as amended,
petitioner claimed a miscellaneous itemized deduction of $3,784
for meals and entertainment related to his employment by Crowley;
the claimed amount took into account the 50-percent limitation
for meals and entertainment provided by section 274(n).
Petitioner reported $5,712 of miscellaneous itemized deductions
for 1994, claiming that he was entitled to deduct $3,377 of that
amount after taking into account the 2-percent floor of section
67. Petitioner has no receipts to support the claimed $3,784
deduction. Petitioner used the per diem substantiation method of
the applicable revenue procedures and ascertained the amount of
that deduction by using the full M&IE rate for each city to which
he traveled. The $3,784 deduction related solely to the
incidental expenses which petitioner paid during 1994 while
working on the Falcon.
On his 1996 Federal income tax return, petitioner claimed a
miscellaneous itemized deduction of $4,912 for business expenses
other than meals and entertainment and a $3,654 miscellaneous
itemized deduction for meals and entertainment; both amounts were
related to his employment by Crowley, and the latter amount took
into account the 50-percent limitation of section 274(n) for
meals and entertainment. Petitioner reported $10,239 of
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