- 34 - employment. See Bryant v. Commissioner, T.C. Memo. 1993-597, affd. 39 F.3d 1168 (3d Cir. 1994). Petitioners have not substantiated the business nexus for any of the claimed automobile expenses for driving to or from petitioner’s law practice, farm, or rental property, or that he incurred auto expenses as a condition of his employment with the IRS. See Dowell v. United States, 522 F.2d 708, 714 (5th Cir. 1975) (each and every element of each and every expenditure must be substantiated). We find, therefore, that petitioner’s testimony and the monthly and yearly mileage reconstructions do not meet the requirements of section 274(d). B. Travel and Meals and Entertainment Expenses 1. Law Practice Petitioners claimed meals and entertainment expenses on Schedule C for 1993 of $559, and travel and meals and entertainment expenses of $151 for 1994. Petitioners provided no acceptable substantiation for entertainment expenses for either year. Of the $559 claimed for meals and entertainment expenses for 1993, $367.34 was expended for a “family get-together” in 1993 on the occasion of the death of Mrs. Reynolds’ mother in Virginia. Petitioner testified that “I went as an individual who was there as a mourner”, but a legal matter arose as to how to handle the estate, which petitioner described as “indigent”. PetitionerPage: Previous 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 Next
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