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$4,386.66 for meals and entertainment where, in petitioners’
words, “there may have been ‘major distractions not conducive to
business discussion’, i.e., sporting events, shows, etc.” (other
entertainment expenses).
For most, but not all, of the restaurant meal expenses,
petitioners have set forth the business purpose of the meal, and
they have attempted to substantiate the claimed business purpose
by referring to the appropriate entry in Randall’s daily planner.
In most, but not all, cases, the actual expenditure of funds has
been substantiated by reference either or both to Randall’s
NationsBank VISA card summary for 1994 or his restaurant receipts
for that year. Unless there is (1) a clearly stated business
purpose for a restaurant meal expense, (2) the item is included
in Randall’s daily planner, thereby supporting the claimed
business purpose, and (3) the expenditure is verified by the
NationsBank summary or by a restaurant receipt, an essential
element of substantiation is lacking, and we sustain respondent’s
disallowance of a deduction for that item.
In reviewing petitioners’ substantiation schedule to
determine the adequacy of the alleged substantiation, we note
that “business purpose” is often referred to in cryptic terms,
e.g., “open”, “close”, “partial”, “A.L. T.D.A.”, “LNL”, “RLTY”,
etc. In some cases, we have been able to decipher the meaning of
the term from Randall’s testimony, and, in some cases, we have
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