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therefore unsubstantiated and disallowed.16 See secs. 162(a),
212(1); Hradesky v. Commissioner, supra at 89-90.
As for the meal, travel, and vehicle expenses that require
strict substantiation, respondent contends that petitioner failed
to substantiate strictly $1,091 in travel expenses and $113 in
meal expenses. Respondent argues that while petitioner
documented his payment of some of the amounts charged, he
substantiated neither the “business purpose” of the expenses nor
the “business relationship” to him of any persons entertained.
We agree that petitioner has not strictly substantiated these
expenses.
Petitioner frequently traveled on business and incurred meal
and travel expenses, which his employer did not reimburse.17 Yet
petitioner substantiated only the time and amount of certain of
these expenses, and of those amounts he did not adequately
establish the business relationship between the expenses and his
business for Selane Products. See sec. 274(d) (flush language).
Petitioner substantiated certain expenses with credit card
receipts and a personal calendar. While some of those expenses
coincided with business functions, petitioner did not explain the
16Petitioner gave us no basis to apply the Cohan rule to
estimate his expenses. See Cohan v. Commissioner, 39 F.2d 540,
543-544 (2d Cir. 1930).
17Petitioner incurred the vehicle expenses for travel
between two Selane Products buildings.
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