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some days during the remainder of the tax year and, on those
days, incurred expenses for meals.
Based upon the foregoing discussion, we find that, for the
1994 tax year, petitioner incurred deductible traveling expenses
(for meals), under the heading: Per diems – Norman Duquette, in
the amount of $3,409 (80% x $4,261).
D. Business Meals With Clients
We allow no deduction with respect to the $1,711 claimed as
“Business meals with clients” (client meals). On brief, in its
discussion of client meals, petitioner merely directs us to the
analyses and other stipulated documents. We have examined those
exhibits and are unable to identify the charges that constitute
the client meals. Moreover, with respect to the group of charges
that might contain the charges for client meals, petitioner has
failed to comply with the substantiation requirements of section
1.274-5T(b)(3), Temporary Income Tax Regs., governing
entertainment of clients. Petitioner has presented no evidence
concerning the specific "business reason" for the meals, the
"nature of business derived or expected to be derived as a result
of the [meals]", or (with few exceptions) the "business
relationship" of the person or persons entertained by
Mr. Duquette. See sec. 1.274-5T(b)(3)(iv) and (v), Temporary
Income Tax Regs. We, therefore, deny any deduction for the
charges for client meals.
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