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expenses”, (2) personal date books for 1993 and 1994, and (3)
photocopied receipts and correspondence for 1993 and 1994. The
“account of expenses” appears to have been prepared in
preparation for this proceeding, and we give it no weight other
than as a summary of items allegedly substantiated by other
documentary evidence. The personal date books contain
handwritten notes with a few numbers that do not appear to
correlate with the numbers in petitioner’s account of expenses.
The receipts and correspondence are incomplete and insufficient
to satisfy the requirements of section 162 and, where applicable,
section 274. For example, most of the documents dealing with
expenses that seem to be covered by section 274 do not provide
the date, amount, place, and essential character of the
expenditure as required by section 1.274-5(c)(2)(iii), Income Tax
Regs.
For the reasons described above, we are unable to discern
any adequate factual or legal basis for allowing petitioner a
deduction for any of the expenses claimed under these
circumstances. Accordingly, we hold that petitioner has not
proven he was entitled to deduct either the meeting payments or
his claimed unreimbursed direct expenses as ordinary and
necessary business expenses under section 162(a).
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