Karan M. Hintze - Page 19

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          relationship to petitioner.  See sec. 1.274-5T(b)(3)(v),                    
          Temporary Income Tax Regs., supra.  Because petitioner has failed           
          to substantiate these deductions pursuant to section 274(d), no             
          deduction is allowed on their account.                                      
               With respect to a number of other meal expenses, however,              
          petitioner provided information, including the name of the                  
          individual entertained, sufficient to establish the business                
          relationship to petitioner.  Through her testimony, petitioner              
          identified these individuals as either plastic surgeons or                  
          representatives of beauty spas who contracted with petitioner for           
          her micropigmentation services.  We find that petitioner has                
          satisfied the substantiation requirements of section 274(d) with            
          respect to these particular expenses, which are enumerated in               
          appendix D and which total $315.41.  After application of the 50-           
          percent limitation contained in section 274(n), petitioner is               
          entitled to a deduction for meal and entertainment expenses of              
               3.   Home Office Expense                                               
               Petitioner claimed deductions of $3,216 and $1,230 for                 
          business use of her home during tax years 1992 and 1994,                    
          respectively.  Respondent disallowed these deductions in their              
               As a general rule, an individual taxpayer is not allowed a             
          deduction with respect to expenses attributable to a dwelling               
          unit which the taxpayer uses as a residence.  See sec. 280A(a).             

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