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entertainment expenses, as well as expenses relating to listed
properties, are subject to strict substantiation requirements
under section 274(d), and this Court is precluded from applying
the Cohan rule to such expenses. Some of the expenses at issue
in this case are subject to the section 274(d) restriction. On
this record, the Court holds that petitioner is not entitled to
deductions for his Schedule C expenses in amounts exceeding those
allowed by respondent. Respondent, therefore, is sustained on
this issue.
The second issue relates to respondent's determination that
petitioner failed to include in gross income on his 1996 return
$1,193 in payments or distributions petitioner received from
Metropolitan Life Insurance Co.
Respondent offered into evidence an Information Returns
Master File Transcript with respect to petitioner for 1996. That
transcript identifies information returns filed by payors of
payments or distributions to taxpayers during a taxable year.
Respondent's transcript lists an information return by
Metropolitan Life Insurance Co. of New York, NY, and the issuance
to petitioner of an IRS Form 1099-R, Distributions From Pensions,
Annuities, Retirement or Profit-Sharing Plans, IRAs, Insurance
Contracts, etc., reflecting a gross distribution to petitioner
during 1996 of $5,348, of which $1,193 was a taxable amount and
from which $119 was withheld in taxes. The transcript does not
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