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Petitioners have failed to do this, and we therefore find that
they have not adequately substantiated these expenses and are not
entitled to these deductions. The copies of checks, in the total
amount of $140, were for the purchase of an armoire used to store
Melaleuca supplies and products. The copies of these checks
which were entered into evidence are not clear, but nothing
appears on them which indicates they were presented for payment.
We nevertheless accept petitioners’ testimony with regard to this
expense, and therefore hold that they are entitled to an
additional deduction in the amount of $140.
The next deductions at issue relate to the Melaleuca meals
and entertainment expenses. Petitioners presented 67 copied
pages of receipts and checks which contained sporadic notations,
for the most part providing only partial details, such as “Mela
mtg” or a person’s name. This substantiation does not meet the
requirements of section 274(d). Furthermore, we find the
receipts are not credible evidence. For example, one receipt was
copied twice, and the copies each had separate notations stating
meetings had occurred with two different persons. The notations
were nearly all made not on the receipt itself, but on the copy
of the receipt. Ms. Nitschke indicated in her testimony
concerning other receipts presented as evidence that the
notations were probably made at the end of the year. Even
accepting this testimony, and not concluding that petitioners
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