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d. Conclusion as to Traveling Expenses
To summarize our findings above, petitioner is entitled to a
deduction of $1,710.93 for domestic traveling expenses and a
deduction of $3,505.32 for foreign traveling expenses.
Furthermore, petitioner is entitled to a deduction of $1,711.99
for expenses which she improperly characterized as traveling
expenses. Adding the $347 deduction for parking expenses
conceded by respondent brings the total deductions to which
petitioner is entitled in respect of the expenses discussed above
to $7,275.24.
2. Meal and Entertainment Expenses
On her tax return for 1994, petitioner reported meal and
entertainment expenses of $560. Pursuant to the limitation
contained in section 274(n), she claimed a deduction for 50
percent of such expenses. Respondent determined petitioner was
not entitled to a deduction for her meal and entertainment
expenses on the ground that petitioner had failed to meet the
substantiation requirements of section 274(d).
Meal and entertaining expenses are subject to the
substantiation requirements of section 274(d). See sec.
274(d)(2). No deduction is allowed for such expenses unless the
taxpayer substantiates by adequate records or by sufficient
evidence corroborating the taxpayer’s own statement each of the
following elements: (1) The amount of each separate expenditure;
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