- 33 - We have held on numerous occasions that merely presenting the Court with a “blizzard” of receipts and other documents “falls woefully short of meeting the requirements” of section 274. Lynch v. Commissioner, T.C. Memo. 1983-173; see Gilman v. Commissioner, 72 T.C. 730 (1979); Rutz v. Commissioner, 66 T.C. 879 (1976). Giving petitioner the benefit of the doubt, however, we have painstakingly scoured petitioner’s documentary evidence in an attempt to decipher whether, in the aggregate or otherwise, petitioner presented adequate records to substantiate any of these alleged travel expenses under section 274. On the basis of our review of all the evidence, we conclude that petitioner has failed to comply with the statutory requirements of section 274. Petitioner’s detailed but highly self-serving and noncredible testimony does nothing to cure these infirmities. Moreover, the record does not establish which, if any, of the expenses at issue were incurred in connection with trips that required petitioner to sleep or rest, within the meaning of United States v. Correll, supra, so as to constitute expenses for travel “away from home” within the meaning of section 162(a)(2). On brief, petitioner suggests that he satisfies the “sleep or rest” rule because the “typical charter flight” was of such duration that FAA requirements would require the pilot to rest for “several hours”. Nothing in the record specifically establishes, however, on which trips petitioner might have rested or for how long, or that the duration of the rest would bePage: Previous 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 Next
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