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testified that he reconstructed significant portions of the
mileage log 2 years after the fact in preparing for trial.
Petitioner also claimed $2,4224 of meals and entertainment
expenses as unreimbursed employee business expenses for 2000.
Petitioner derived this number from the yearend summary statement
he received from a credit card company that grouped restaurant
and entertainment expenses together (master credit card summary).
Petitioner admitted that he did not use this account exclusively
for business purposes. The master credit card summary showed
$2,168 under the category “Restaurants” and $232 under the
category “Entertainment”.5 The master credit card summary listed
only the date, the name of the restaurant or other payee, and the
amount of the item. The master credit card summary did not list
the name of the business contact being entertained nor the
business purpose for the expense. Petitioner created another
document 6 months before trial, which was approximately 3-1/2
years after the fact, on which he listed the name of the person
with whom he dined, his business relationship with the person,
the name of the restaurant, the business purpose, and the amount
for each meal (reconstructed entertainment list). The total
4This total amount of meals and entertainment expenses was
reduced by 50 percent. Sec. 274(n)(1)(A). Petitioner therefore
claimed $1,211 for meals and entertainment expenses for 2000.
5There is a $22 difference between the sum of these two
amounts and the total meals and entertainment expenses petitioner
claimed. We assume this difference was a computational mistake.
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