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stipulation of facts, and we were unable to find any reference at
trial to these alleged fees. Petitioner’s brief contains no
citation of the record to support this claim.
Petitioner alleges on brief that $315,000 was paid to Alpine
Industries for cost of goods sold. There is no evidence in the
record to support petitioner’s contention that he made payments
of $315,000 to Alpine Industries. Indeed, petitioner’s tax
adviser, Carroll, testified that the cost of goods sold amount
was based primarily on payments made from one of petitioner’s
bank accounts to another (which was held in the name of the “Claw
trust”). Respondent conceded a deduction of $8,924 for amounts
petitioner paid to Alpine Industries. Petitioner has not
substantiated any portion of the balance of the amount claimed.
Petitioner states on brief that he should be allowed to
deduct $7,436 in car expenses for his travel between his Fresno
and Merced offices. Petitioner must meet the strict
substantiation requirements of section 274(d) with respect to
travel expenses. Except as otherwise provided in the
regulations, section 274(d) requires the taxpayer to substantiate
with adequate records or sufficient evidence corroborating his
own statements: (1) The amount of the expense, (2) the time and
place of the travel, and (3) the business purpose of the expense.
Under the regulations, to meet the “adequate records” requirement
of section 274(d), a taxpayer “shall maintain an account book,
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