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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.
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