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but not all, of the checks18 contained a notation indicating that
they were for either travel, entertainment, or travel and
entertainment. However, petitioner did not provide any
information regarding the amount of each expense, the time and
place of each activity, the business purpose of the activity, or
petitioner’s business relationship to the person entertained.
Petitioner did not produce copies of the receipts and/or monthly
account statements from Diners Club, Citibank, MBNA, or American
Express. Rather, petitioner simply asserts that it would have
been impossible to reconstruct his meals and entertainment
expenses without receipts. We sustain respondent's disallowance
of these deductions.
3. Repairs and Maintenance
Petitioner claims repair and maintenance expenses of $396.40
in 1993 and $5,767.43 in 1994. Petitioner testified that his
office incurred water damage, and in order to minimize the cost
18The checks in 1993 totaled $12,286.76, while petitioner
reported total travel, meals, and entertainment expenses of
$18,797 before application of the limit on meals and
entertainment expenses under sec. 274(n). Additionally, the
checks in 1994 totaled $9,492.32, while petitioner reported total
travel, meals, and entertainment expenses of $16,042 before
application of the limit on meals and entertainment expenses
under sec. 274(n). Petitioner offered no explanation for the
difference in the amounts reported and the checks provided to
substantiate his expenses.
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