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which the payments were allegedly made such as “briefing,”
“training”, and “dues”. Except for the signature of the
individual in charge of collecting those fees (which is
frequently that of petitioner herself), however, the receipts do
not disclose any information regarding the identity of the payee,
the business purpose, or the nature of the expense. Petitioner
has failed to provide us any additional credible information that
these expenses are related to, or were required by, her business.
Accordingly, we agree with respondent’s determination disallowing
these deductions.
3. Gifts and Meals and Entertainment
Petitioner disputes respondent’s disallowance of $162 and
$311 in expenses she incurred for business gifts in 1999 and
2000, respectively. She also claims that respondent erred in
denying her deductions for meals and entertainment expenses of
$261 for 1999 and $1,114 for 2000.
As discussed above, both business gifts and meals and
entertainment expenses are subject to the substantiation
requirements of section 274(d). See sec. 274(d)(2) and (3). Yet
the only evidence petitioner submitted to substantiate her gifts
and business meals and entertainment expenditures is receipts on
which she has notated “gifts for client” or “meeting with [name
of the individual]”. Petitioner has not proffered any
information regarding the business purpose of the expenses, her
business relationship with the recipient of the gift or the
individual entertained, or any other information that would
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