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amount, time and place, and business purpose of the expense, as
well as the business relationship to the taxpayer of the persons
involved in the claimed expenses. Id. (flush language).
Adequate records require the taxpayer to maintain a diary, a log,
or a similar record, and documentary evidence that, in
combination, are sufficient to establish each element of each
expenditure or use. Sec. 1.274-5T(c)(2)(i), Temporary Income Tax
Regs., 50 Fed. Reg. 46017 (Nov. 6, 1985). A record must
generally be written contemporaneously with the expenditure.
Sec. 1.274-5T(c)(2)(ii)(A), Temporary Income Tax Regs., supra.
Against this background, we now analyze whether petitioner
satisfied substantiation requirements for his claimed deductions.
Overall, petitioner claimed $17,500 in business expenses of
which he conceded $833. Of the remaining $16,667, $15,745 was
attributable to the tuition expenses that petitioner
substantiated, for which we granted a deduction. The remaining
amounts are $922 in miscellaneous business expenses, $40 in tax
preparation fees, $104 in vehicle expenses, $1,091 in travel
expenses, and $113 in meal expenses.
Petitioner contends that he lost records supporting expense
deductions for the tax preparation fees and miscellaneous
business expenses. He has failed to reconstruct adequately those
records or otherwise corroborate those items. These expenses are
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