Daniel R. Allemeier, Jr. - Page 22

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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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