Daniel A. Aregoni - Page 10

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          documents in the record before this Court.  Petitioner claims               
          that Merrill Lynch will not turn over the documents.  Respondent            
          notified petitioner of the possibility of subpoenaing the                   
          documents and continuing this case in an attempt to obtain them.            
          Petitioner did not avail himself of the opportunity either to               
          continue this case or to subpoena the alleged documents.                    
               Moreover, petitioner testified that he could not explain, as           
          to each entertainment expenditure, who he met with or what the              
          expense was incurred for, and he could not explain as to airline            
          expenditures what was the objective of the trip or the                      
          destination.  As to the other claimed job expenses and                      
          miscellaneous deductions, petitioner stated:  “It’d be impossible           
          to give * * * the exact name and prospect” for each expenditure.            
               We have taken into consideration petitioner’s testimony and            
          incomplete records, and we conclude that petitioner failed to               
          satisfy the requirements of sections 162 and 274 as to any                  
          expenditures in excess of the $19,285 respondent conceded.                  
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   

                                             Decision will be entered                 
                                        under Rule 155.                               










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