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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 be
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