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any weight. Petitioner mentioned many individuals as
participants in his efforts, but none of these people testified.
Accordingly, we find that petitioner has failed to substantiate
his claimed traveling expenses.
Petitioner also failed to establish the amount or business
purpose of the claimed telephone expenses. At trial, petitioner
attempted to substantiate the claimed telephone expenses by
presenting copies of telephone bills. Contrary to petitioner’s
argument, these telephone bills do not establish the business
purpose for the telephone expenses. The bills could represent
personal calls as easily as they could business calls.
Petitioner attempted to substantiate the claimed car and
truck expenses and meals and entertainment expenses by
introducing a mileage log and a diary. Contrary to petitioner’s
assertions, the mileage log and diary do not substantiate these
expenses. At trial, petitioner testified that the diary
represented expenses paid by his brother, who died in India prior
to trial. Petitioner also testified that the mileage log
represented car and truck expenses incurred by his brother.
Petitioner also stated that most of the entries in the log had
been made by his brother’s driver in India. The business
function of the travel has not been established. Petitioner’s
brother was a practicing physician in India, and the record does
not show whether the expenses he allegedly paid were for his
medical practice, were personal, or were for some aspect of the
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