Robert C. and Carol S. Jacobsen - Page 7

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               Petitioners are not entitled to estimate deductible car and            
          truck expenses without the substantiation of time, place, and               
          business purpose required by section 274(d).  See also section              
          280F(d)(4) with respect to expenses relating to passenger                   
          automobiles.  Despite the volume of paper presented by                      
          petitioners, they have failed to satisfy the strict                         
          substantiation requirements of the applicable law.  Even if we              
          could accept Mr. Jacobsen’s generalized testimony and assertions            
          that all of the mileage related to attempts to secure business              
          and to make contacts, the amount is unreasonable in view of his             
          testimony about the severity of Mrs. Jacobsen’s illness during              
          1997.  On this record, no deduction for car and truck expenses or           
          meals and entertainment expenses may be allowed.                            
          Legal Expenses                                                              
               Respondent contends that there is no evidence substantiating           
          petitioners’ claim that they incurred legal expenses during 1997            
          that were deductible as business expenses.  Again, petitioners              
          presented fragmentary documents that showed that certain payments           
          were made.  Neither the documents nor Mr. Jacobsen’s testimony              
          adequately or persuasively explained how the expenses related to            
          his business.  His testimony about the various matters discussed            
          with regard to the services provided by the lawyer to whom                  
          payment was made suggests items that are not currently                      
          deductible.  Mr. Jacobsen testified:                                        

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