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3. Travel
Petitioner claimed a deduction of $5,892 for travel
expenses. Petitioner testified that when he would drive a
customer home late at night, he would occasionally stay in a
hotel instead of driving back. Petitioner also stated that there
were conferences he attended on the island and seminars in
Arizona. Petitioner could not recall whether any of these events
occurred in 1993. Petitioner did not provide any records or
reconstructed records, nor were there any notations in his
calendar, about any of these events. On the basis of this
record, petitioner has not met the strict substantiation
requirements of section 274(d), and he is not entitled to a
deduction for travel expenses.
4. Business
Petitioner claimed a deduction of $6,986 for business
expenses. According to petitioner’s testimony, these expenses
were for items purchased, such as gifts and gasoline, to secure
sales. In petitioner’s calendar, he recorded the items he
purchased for customers, such as hats, t-shirts, and bikini tops
(a vinyl covering for certain vehicles). When a customer’s
vehicle was not ready on the day of purchase, petitioner would
give the customer a loaner car and would fill up the tank with
gasoline. For some months, petitioner listed at the bottom of
the calendar page the amount he incurred with respect to gifts
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