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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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