- 30 - 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).Page: Previous 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 Next
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