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of the travel, entertainment, etc., the business purpose, and the
business relationship of persons being entertained.
Petitioner claimed to have logs and other documentary
evidence regarding these claimed expenses, but he did not produce
them or offer them into evidence. Because of the rigorous
requirements for substantiation for expenses of this variety, his
uncorroborated testimony will not suffice, and we accordingly
sustain respondent’s determination disallowing petitioner’s
travel, entertainment, and related expenses.
IX. Dependency and/or Personal Exemptions
On his 1987 through 1991 returns, petitioner claimed
dependency exemptions for his four children and a personal
exemption for Mrs. Corrigan. Respondent conceded that petitioner
was entitled to file his returns as head of household for 1987
through 1991, and that petitioner was entitled to dependency
exemptions for David in 1987 through 1989, Erin in 1987 through
1991, Robert in 1987 and 1991, and Amy in 1991. All other
dependency exemptions and the personal exemptions have not been
conceded and were determined not allowable by respondent.
Section 151(c) provides for a deduction for each dependent
(as defined in section 152). A “dependent”, among others, can be
a son or daughter “over half of whose support, for the calendar
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