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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
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