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3. “Trade Missions”, Overseas Expenses
On his Schedules C for 1999 and 2000, petitioner claimed
deductions for “trade missions” in the amounts of $11,900 and
$6,975, respectively. Also on his Schedules C for 1999 and 2000,
petitioner claimed various overseas expenses in the aggregate
amounts of $24,720 and $29,450, respectively.16
To the extent that the strict substantiation rules of
section 274(d) apply, petitioner has not adequately substantiated
any of the foregoing deductions. See sec. 274(d); sec. 1.274-
5T(a), Temporary Income Tax Regs., 50 Fed. Reg. 46014 (Nov. 6,
1985); see also sec. 6001; sec. 1.6001-1(a), Income Tax Regs.
To the extent that the strict substantiation rules of
section 274(d) would not preclude us from estimating an
appropriate allowance, any such estimate would be unfounded. See
Williams v. United States, 245 F.2d at 560.
In addition to the foregoing, we are not convinced that the
amounts claimed are even deductible, apart from their lack of
substantiation. In this regard, the record demonstrates that
shortly after petitioner returned from his first “trade mission”
(December 22, 1999, to January 7, 2000), Americana Business
Consultants (Nigeria) Limited, a Nigerian corporation, was
incorporated. At trial, petitioner testified that he was obliged
16 For 2000, the aggregate amount consists of rent of
$3,900, wages of $16,000, office expenses of $1,680, and other
expenses of $7,870.
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