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business relationship between the charges and the trade or
business of Selane Products.18 For example, petitioner’s credit
card statement listed a charge for “Tavern on the Green” on
November 29, which coincided with a calendar notation for
“greater New York Dental Meeting.” We do not know with whom
petitioner dined, whether the dinner had a business purpose, or
the nature of the relationship, if any, between the person
entertained and petitioner’s work for Selane Products.
Petitioner’s credit card statement also listed a charge for
“Monterey Plaza Hotel” on October 29, which coincided with a
calendar notation for “Monterey Meeting.” We are left to
speculate as to the nature and business purpose of the Monterey
Plaza charge.
For these charges, petitioner was subject to stricter
substantiation requirements than for his general business
expenses. We find that petitioner has failed to satisfy those
requirements. Accordingly, we sustain respondent’s
determinations regarding petitioner’s unreimbursed business
expenses.
18Credit card receipts reflect that petitioner paid $671.87,
$231.40, and $100.50 for a hotel, rental car, and airline fare,
which coincided with a business convention. Petitioner similarly
substantiated that he paid $130.33 and $116.66 in restaurant
charges during another business convention.
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