- 43 -
IRS, an attorney, and a certified public accountant. With his
background, he has a wider range of technical expertise in tax
matters than do members of the general public. See Lagoy v.
Commissioner, T.C. Memo. 1992-213; Jenkins v. Commissioner, T.C.
Memo. 1988-292, affd. without published opinion 880 F.2d 414 (6th
Cir. 1989). He is, or certainly should be, familiar with the
substantiation requirements of section 274, and he had access to a
wide range of tax resources relating to his claimed deductions
under sections 162 and 274. Petitioners knew or should have known
that they had to substantiate the deductions they claimed and had
to establish both the amount and business, as opposed to personal,
nature of the expenditures. Accordingly, respondent’s
determination is sustained.
We have considered the other arguments of the parties, and
they are either without merit or not necessary in view of our
resolution of the issues in this case.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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