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travel lack any specificity.4 In short, we do not find that
petitioner’s records satisfy the requirements of section 274(d).
We sustain respondent’s determination as to the automobile
expenses.
2. Travel and Meals.--Petitioners claimed deductions of
$2,100 and $1,560 for travel and meals, respectively. Respondent
allowed $649 and $500, respectively. As to the travel, section
274(d) requires that travel expenses be substantiated by evidence
establishing the amount of the expense, the business purpose for
the travel, and the time and place of the travel. Petitioners
introduced no receipts or other evidence to show the amounts paid
or the business purpose of the travel. With respect to the
meals, petitioner contends that he is entitled to use the so-
called per diem substantiation. See Rev. Proc. 94-77, 1994-2
C.B. 825. But, to use the per diem method in lieu of strict
substantiation, a taxpayer still must “[substantiate] the
elements of time, place, and business purpose of the travel
expenses in accordance with” the regulations under section
274(d). Rev. Proc. 94-77, sec. 4.03, 1994-2 C.B. at 827; see
Reynolds v. Commissioner, T.C. Memo. 2000-20. As we have noted,
3(...continued)
roundtrip mileage.
4 Petitioner’s records state that the reason for many of the
trips was to attend a “Conference” without any description of the
nature of the conference.
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