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expenses with respect to certain items. See Sanford v.
Commissioner, 50 T.C. 823, 827 (1968), affd. per curiam 412 F.2d
201 (2d Cir. 1969). Section 274(d) imposes strict substantiation
requirements for gifts, travel, entertainment, and meal expenses.
See sec. 1.274-5T(a), Temporary Income Tax Regs., 50 Fed. Reg.
46014 (Nov. 6, 1985). To obtain a deduction for a travel, meal,
or entertainment expense, a taxpayer must substantiate by
adequate records or sufficient evidence to corroborate the
taxpayer’s own testimony the amount of the expense, the time and
place where it was incurred, the business purpose of the expense
and, in the case of entertainment, the business relationship to
the taxpayer of each person entertained. See sec. 274(d); sec.
1.274-5T(b), Temporary Income Tax Regs., 50 Fed. Reg. 46016 (Nov.
6, 1985). If a taxpayer is unable to fulfill the requirements of
section 274(d), then he is not entitled to the deduction.
2. Depreciation
Section 167(a) permits a depreciation deduction for the
exhaustion, wear and tear of property used in a trade or
business. Petitioner claimed depreciation deductions of
$51,222 in 1990, $30,703 in 1991, and $31,203 in 1993.
Petitioner failed to demonstrate that the depreciated properties
were used in his trade or business. Further, petitioner did not
identify the properties he depreciated. We are unable to
estimate an amount for depreciation deductions because petitioner
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