Richard and Judith Haeder - Page 33




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          concession or abandonment of the issue.  See Rule 151(e)(5);                
          Lencke v. Commissioner, T.C. Memo. 1997-284.                                
               Our review of the record convinces us that petitioners have            
          failed to satisfy the stringent substantiation requirements of              
          section 274(d) as to any travel, meal, and entertainment expenses           
          not allowed by respondent.  Accordingly, we hold that petitioners           
          are not entitled to additional deductions for travel, meal, and             
          entertainment expenses beyond the amounts allowed by respondent             
          or as stipulated by the parties.                                            
          Bad Debt Deduction                                                          
               Petitioner claimed a deduction on his Schedule C for 1991              
          for a bad debt.  Petitioners contend that petitioner is entitled            
          to deduct the payment as an expense of his law practice.                    
               Respondent contends that petitioner gave $300 to family                
          friends and that the payment did not create a bona fide debtor-             
          creditor relationship.  Respondent also contends that petitioners           
          have not shown that, if the payment was a valid debt, it became             
          worthless during 1991.                                                      
               Section 166(a) authorizes a deduction for a business bad               
          debt that becomes worthless during the year.11  To be entitled to           

               11Sec. 166 distinguishes between business and nonbusiness              
          bad debts.  Nonbusiness bad debts of taxpayers other than                   
          corporations are short-term capital losses.  See sec.                       
          166(d)(1)(B).  A nonbusiness debt is a debt other than “(A) a               
          debt created or acquired (as the case may be) in connection with            
          a trade or business of the taxpayer; or (B) a debt the loss from            
                                                              (continued...)          





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