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is allowable (1) for traveling expenses, (2) for entertainment
expenses, (3) for expenses for gifts, or (4) with respect to
listed property. Listed property includes passenger automobiles
and other property used as a means of transportation. Sec.
280F(d)(4). To meet the strict substantiation requirements, the
taxpayer must substantiate the amount, time, place, and business
purpose of the expenses. Sec. 274(d); sec. 1.274-5T, Temporary
Income Tax Regs., 50 Fed. Reg. 46006 (Nov. 6, 1985).
Petitioners presented evidence of numerous credit card
interest payments made during the years in issue, purportedly in
connection with the writing/lecturing business. They dispute
respondent’s determination of the percentage of these expenses
that was business rather than personal. However, they did not
provide the Court with a more reliable method of ascertaining the
correct percentage, and they did not otherwise show more interest
to be deductible than that which was determined to be so by
respondent.
Petitioners presented no evidence to substantiate the
claimed itemized deductions. They testified that some of their
substantiating documents had been destroyed when repair work had
been done on or around their condominium apartment. However,
petitioners did not provide the Court with any reliable method by
which we could estimate any deductible expenses.
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