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(2) the date of entertainment; (3) the name, if any, address, or
location of the entertainment; (4) the business reason for the
entertainment or the nature of the business benefit derived or
expected to be derived as a result of the entertainment and the
nature of the business discussion or activity; and (5) the
occupation or other information relating to the person or persons
entertained, including the name, title, or other designation,
sufficient to establish the business relationship to the
taxpayer. See sec. 274(d); sec. 1.274-5T(b)(3), Temporary Income
Tax Regs., 50 Fed. Reg. 46015 (Nov. 6, 1985).
At trial, petitioner produced 29 receipts containing various
notations which she contends substantiate business meal expenses
in the amount of $1,600.13. Two of the receipts, totaling $500,
represent expenses for food which petitioner provided at her
seminars in Denmark. We addressed those expenses in our
discussion of petitioner’s traveling expenses and shall not
consider them here.12 With respect to the remainder of
petitioner’s receipts, most of them contain only a notation
identifying the individual or individuals entertained as “client”
or “clients”. With respect to these expenses, petitioner has
failed to provide adequate information relating to the person or
persons entertained sufficient to establish the business
12 Petitioner was allowed a deduction for these expenses on
the ground that they were not subject to sec. 274(d). They are
included as items 4 and 5 in appendix A.
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