- 42 -
In conclusion, petitioner is not entitled to his claimed
deductions for unagreed travel expenses.
14. Entertainment Expenses
Petitioner seeks to deduct as entertainment expenses $13 and
$31, respectively, for two meals that he alleges were business
related. Deductibility of these items is governed by section
274. See sec. 274(d)(2). Petitioner failed to offer direct
evidence substantiating the amount, time, place, or date of these
claimed entertainment expenditures. See sec. 1.274-5(c)(3),
Income Tax Regs. Accordingly, petitioner is entitled to no
deduction for his alleged entertainment expenses.
15. Alleged Interest Payments to Petitioner’s Mother
Petitioner alleges that he borrowed money from his mother
during the subject years to fund his aviation activities. He
seeks to deduct three checks totaling $941 allegedly paid to his
mother for interest on the alleged loan. He concedes that there
is no documentary evidence of either the loan or his obligation
to repay his mother.
Section 163(a) generally allows a deduction for “all
interest paid or accrued within the taxable year on
indebtedness.” Indebtedness means an unconditional and legally
enforceable obligation for the payment of money. See Autenreith
v. Commissioner, 115 F.2d 856, 858 (3d Cir.), affg. 41 B.T.A. 319
(1940); Linder v. Commissioner, 68 T.C. 792, 796 (1977).
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