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if one was, the cost thereof or the flight itinerary. Regarding
the other enumerated expenses, petitioner claims to have paid in
cash; he also claims that in Nigeria hotels, restaurants, and
other purveyors of goods and services do not provide receipts.6
On his Schedule C for 2000, petitioner claimed a deduction
for “trade mission” in the amount of $6,975. In this regard,
petitioner claims to have gone to Nigeria on another “trade
mission” from December 25, 2000, to January 13, 2001. The record
does not include any schedule of expenses that petitioner claims
to have incurred. The record does include a flight itinerary
issued by a travel agency in Houston calling for the payment of
$1,930 and a passenger receipt showing a fare of “BULK” and tax
of $88.73. No other documentation exists in the record;
petitioner again claims to have paid his expenses in Nigeria in
cash.
At trial, petitioner testified that he went to Nigeria on
“trade missions” during the holiday season not because his family
was there (see infra I.D., note 8) but because:
In Nigeria business is mostly done during December
time. Done during December time, because at that time
you have gifts to give to people. They’re happy. So
this is the only time they can talk to you.
6 According to petitioner, “Everything in Nigeria is cash”
and “there is nothing like a receipt.”
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