- 6 - the loss of such records, but he has not offered any reconstruction of his expenditures. There is no evidence in the record to substantiate adequately the section 162(a) expenses in excess of those conceded by respondent. In addition, we believe that petitioner did make some business trips during the years in issue, but there is insufficient evidence to determine the facts required by section 274(d). Thus, petitioner is not entitled to deduct such expenses, and, pursuant to Lone Manor Farms, Inc. v. Commissioner, 61 T.C. 436, 440 (1974) (stating that the Court may compute “the correct tax liability for a year not in issue when such a computation is necessary to a determination of the correct tax liability for a year that has been placed in issue”), the carryovers from 1992 and 1993 shall be computed accordingly. III. Employee Business Expense Deductions On Forms 2106, Employee Business Expenses, of his 1994, 1995, and 1996 returns, petitioner claimed employee business expenses of $20,103, $56,137, and $24,903. We conclude that the record contains evidence sufficient to substantiate section 162(a) deductions of $3,804, $33,419, and $6,056, relating to the respective years in issue, but not the deductions governed by section 274(d) (i.e., travel, meal, entertainment, and gift expenses).Page: Previous 1 2 3 4 5 6 7 8 Next
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