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made the notations in anticipation of trial, we find it unlikely
that petitioners could have accurately remembered the business
purpose and persons with whom they dined for these numerous
expenses--which included items such as fast food meals--for up to
a year beyond the date of the expense. Petitioners also
presented a summary of these meal and entertainment expenses,
listing amount, business purpose, time, location, and business
contact. The amount of expenses contained in the summary,
$2,352.73, does not match the amount of expenses claimed on the
return, $3,277. We do not accept this summary as substantiation
for the same reasons we do not accept the underlying receipts as
substantiation. We therefore uphold respondent’s determinations
with respect to these deductions.
The next deductions at issue relate to the Melaleuca travel
expenses. Petitioners presented receipts with a cover sheet
stating that travel expenses for 1995 totaled $4,467.
Petitioners claimed $2,835 of travel expenses on their return.
We find that this substantiation presented by petitioners also
does not meet the strict substantiation requirements of section
274(d) because the amount, time, place, and business purpose of
the expenses were not established. We therefore uphold
respondent’s determinations with respect to these deductions.
The next deductions at issue relate to the Melaleuca “other
expenses.” Petitioners presented 115 copied pages of receipts
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