Daniel R. Allemeier, Jr. - Page 20

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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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