David J. Edwards - Page 28





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               Second, petitioner’s travel expenses are subject to the                
          strict substantiation requirements of sections 274(d) and                   
          280F(d)(4)(ii).  Petitioner failed to substantiate the amount of            
          his expenses or the time, place, and business purpose of his                
          travel.  Petitioner’s “flight log” was not legible and did not              
          contain the specific information required by section 274(d), such           
          as the business purpose of each flight.  Petitioner claimed that            
          the airplane was used for travel to and from his Burbank office,            
          for travel to business meetings (none of which were                         
          substantiated), and for maintaining his flying proficiency which            
          he claims is “helpful”, but not strictly required, for                      
          maintaining his status as a medical examiner for airline pilots.            
          Petitioner’s compliance with the strict substantiation                      
          requirements of section 274(d) is necessary in order to enable              
          the Court to determine the percentage of business use and thus              
          the allowable amount of petitioner’s claimed deductions.  See               
          Noyce v. Commissioner, 97 T.C. 670 (1991) (treating flight                  
          training, personal use, and maintenance flights as nonbusiness              
          use and allowing deduction only for business-use portion of                 
          expenses).                                                                  
               With respect to deductions other than depreciation,                    
          petitioner must establish that the expenditures were ordinary,              
          necessary, and reasonable.  Id. at 685; Marshall v. Commissioner,           
          T.C. Memo. 1992-65.  To establish that the expenses are ordinary,           






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