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deduction otherwise allowable under section 212 for any traveling
expense, including meals and lodging while away from home, sec.
274(d)(1), and for any item with respect to an activity that is
of a type generally considered to constitute, inter alia,
entertainment, such as a meal expense paid by a taxpayer for a
guest, sec. 274(d)(2), unless the taxpayer substantiates by
adequate records or by sufficient evidence corroborating the
individual’s own statement the amount of such expense, the time
and the place of the travel and entertainment, the business
purpose of the expense, and the business relationship to the
taxpayer of any person entertained. Rules for substantiation of
each element of an expenditure for traveling and for
entertainment are prescribed by section 1.274-5T, Temporary
Income Tax Regs., 50 Fed. Reg. 46014-46018 (Nov. 6, 1985).
According to petitioner, the 1997 document, the claimed car
rental receipt, taxi receipt, and meal receipts and his testimony
establish that he is entitled under section 212 to deduct the
expenses at issue. As we indicated above, we shall not rely on
that evidence in determining whether petitioner has carried his
burden of establishing that he is entitled under section 212 to
deduct those expenses. On the record before us, we find that
petitioner has failed to carry his burden of proving that the
expenses at issue constitute ordinary and necessary expenses paid
or incurred for the production or collection of income and/or for
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