- 33 - 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...)Page: Previous 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 Next
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