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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.
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