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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).
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