- 22 - petitioner made in the years leading up to trial, we believe that petitioner could have substantiated many of the deductions. Moreover, petitioner contemporaneously recorded the time and amount of several business expenses. Though the records were insufficient to meet the strict substantiation requirements, we find that he acted with reasonable cause and in good faith in taking the deductions. Secs. 162(a), 274(d). Accordingly, we decline to impose a penalty upon petitioner. In reaching our holding, we have considered all arguments made, and, to the extent not mentioned, we conclude that they are moot, irrelevant, or without merit. To reflect the foregoing and the concessions of the parties, Decision will be entered under Rule 155.Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22
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