- 10 - he failed to bring the diary to court. He also testified that he based the expense on the number of days away from home for business. Petitioner testified that he was away from home 38 nights in 1996. The record is absent any information as to the number of nights petitioner was away from home in 1997. Section 274(d) provides a strict substantiation rule which does not permit us to make a Cohan estimation. Cohan v. Commissioner, supra. Petitioner is allowed a deduction only for travel expenses properly substantiated by receipts or other evidence corroborating his own statement. Because petitioner is unable to substantiate these deductions, he is not entitled to deduct the amounts claimed as miscellaneous itemized deductions. We also find that petitioner failed to substantiate the meals and entertainment expense deduction. Accordingly, we cannot allow him the deduction for meals and entertainment in 1996. At trial petitioner substantiated union dues of $221 for 1996. Petitioner failed to substantiate the dues claimed for 1997. Accordingly, petitioner is entitled to deduct $221 for union dues incurred in 1996 and none for 1997. We have considered all of the other arguments made by petitioners, and, to the extent we have not addressed them, conclude they are without merit.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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