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could not locate the documents from his office. Third,
petitioner relocated boxes of documents from his office to his
personal residence after his secretary died. Petitioner claims
that his basement was flooded and some of the boxes were
destroyed.
Petitioner failed to meet the strict substantiation
requirements of section 274(d). Petitioner did not establish
through either documents or testimony the amount of each expense,
the time and place where it was incurred, the business purpose of
the expense and, in the case of entertainment expenses, 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). Petitioner’s scant testimony
that he traveled to Europe to meet with banks and trusts falls
short of the rigors of section 274(d). We sustain respondent’s
determinations as to these items.
C. Interest and Dividend Income
Respondent determined that petitioners failed to report
dividend and interest income of $95 in 1990, $5,493 in 1991, and
$253 in 1993. Petitioners do not dispute that they received the
amounts in each year. Petitioners have not presented any
arguments that such income is not subject to tax.
Section 61(a)(4) and (7) defines gross income as including
income from any source, including interest and dividends.
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