Robert B. and Betty D. Harris - Page 25




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               Expense          1994           1995           1996                    
               Car & truck    $3,840.61      –-             $1,722.89                 
               Travel         7,627.35       $6,669.83      3,752.40                  
               Meals & ent.   385.39         1,385.75       306.31                    
               Other:                                                                 
                    Parking   358.55         –-             190.40                    
                    Lodging   –-             1,965.39       814.14                    

          In support of these expenses, petitioners produced various                  
          receipts and statements purporting to show the actual                       
          expenditures.  However, petitioners failed to produce credible              
          evidence, if any evidence at all, as to the business purpose of             
          each expense.  Moreover, petitioners failed to introduce evidence           
          establishing the business relationship to petitioner with any               
          persons purportedly being entertained or using the facilities or            
          property rented by petitioner.                                              
               Petitioners’ evidence with respect to these expenses does              
          not satisfy the stringent substantiation requirements of section            
          274(d).  Moreover, as noted earlier, the Court cannot allow or              
          estimate an allowable deduction for any of these expenses under             
          the Cohan rule.  Thus, the Court holds that petitioners are not             
          entitled to deduct any of the claimed expenses for the years at             
          issue in excess of what was allowed by respondent.8                         


               8    As stated previously, respondent conceded that                    
          petitioners are entitled to deductions for meals and                        
          entertainment expenses (prior to the 50-percent limitation)                 
          totaling $112.45 for 1994.  This amount will be taken into                  
                                                             (continued...)           





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