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Petitioner failed to produce documentation or corroborative
evidence to comply with the strict substantiation requirements of
section 274(d); therefore, petitioner is not entitled to
deductions for meals and entertainment expenses in excess of the
amounts allowed by respondent for 1991, 1992, and 1993.
Petitioner did not contemporaneously annotate receipts indicating
the place, date, amount, and business purpose of the meal. At
the request of Revenue Agent Valerie Schwartz (Ms. Schwartz),
petitioner provided a list identifying the date, place, amount,
business relationship, business purpose, and resulting sales, if
any, for the meals and entertainment expenses. The list was
created in 1996 for Ms. Schwartz during petitioner’s examination.
Although petitioner claims that similar worksheets were created
for all the years in issue, only the 1992 worksheet was provided.
We question petitioner’s ability to remember such minute details
over as much as a 5-year time period for hundreds of meals and
entertainment engagements. Not only does petitioner fail to
follow the strict substantiation requirements, the Court has the
discretion to disregard testimony which we find self-serving.
See Niedringhaus v. Commissioner, supra at 212.
Respondent is sustained on this issue.
3. Gifts
Petitioner claimed a deduction for business gifts of $640,
$683, and $2,643 in 1991, 1992, and 1993, respectively.
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