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Respondent allowed $205, $142, and $25, respectively.
Petitioner’s receipts submitted during trial substantiate
the following amounts: $0 for 1991, $120.62 for 1992, and $0 for
1993. As a threshold issue, petitioner failed to substantiate
the amounts of the claimed deductions. Next, petitioner
testified at trial that some of the “business gifts” included
personal gifts to her mother. Petitioner has the burden to show
how a business gift was “ordinary and necessary” to her business
and that it was made with the reasonable expectation of a
commensurate financial return. Petitioner has not met this
burden.
The scanty documentary evidence, in conjunction with
petitioner’s own statements, does not constitute the adequate
records and substantiating documentation as required by the
statute and regulations. See Sanford v. Commissioner, 50 T.C.
823 (1968), affd. 412 F.2d 201 (2d Cir. 1969). Accordingly, we
sustain respondent’s determination with respect to this issue.
4. Car and Truck Expenses
At trial, petitioner conceded respondent’s determination
that 80 percent of petitioner’s truck expenses in 19912 were for
business purposes. For the taxable year 1991, petitioner
2 The parties agree that the arguments for 1991 apply to
1992 and 1993, and, therefore, our analysis will have the same
effect on all the years in issue.
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