- 13 -
resorts and what appear to be uniquely personal charges. In
addition, petitioner could not explain the discrepancy between
the $763 shown on the reconstructed entertainment list and the
$2,422 he had claimed. Nor could petitioner explain multiple
discrepancies between the master credit card summary and his
reconstructed entertainment list. Moreover, petitioner failed to
produce receipts or any other corroborating evidence to comply
with the strict substantiation requirements of section 274(d).
Accordingly, we sustain respondent’s disallowing the meals and
entertainment expenses.
To reflect the foregoing and the concessions of the parties,
Decision will be entered
under Rule 155.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13
Last modified: May 25, 2011